Bill Presson

This is actually some progress, but I would take the additional step of having your new atty contact Northrup and Fidelity with a formal request. That usually helps move things along.

If the account contains money of several employees, it's not an IRA.

Maybe take a pass on this client and save the headaches?

While true, how many business M & A transactions have you seen where the attorney's didn't even consider the impact of the retirement plan?

Thanks EBE & David. That does make a difference to me.

But let's still assume that they are legally unrelated for tax/retirement plan purposes. If I'm a board member on Org B and not on Org A, I would be very concerned.

If it isn't a contribution, what could it possibly be?

Correct, as long as the client hasn't received a letter from the DOL.

No.

If organization B isn't controlled by the same board as organization A, why would the board of org B agree to do this? And aren't they violating their duty to org B?

The delay wasn't caused by the TPA. The delay was caused by the client not paying their bills. File DFVCP.

Then I can't imagine how it's not a PT.

Paid to the employer???

Your w-2 sentence answers your question.

Agree with Gilmore and with Jak.

Agree with this. Be careful the document allows what you're trying to do.

When I first read the title, I couldn't figure out how how a cancellation created a powerpoint.

I really think you should be asking your actuary and CPA these questions.

This is why I recommend allowing changes each payroll. Employers are so wary of this, but it's very rarely an issue. The only way this might not fix the issue is if the bonuses are paid on a regular paycheck and not separately.

https://www.napa-net.org/news-info/daily-news/nyc-moves-establish-auto-ira-program

And the sponsor keeps it as evidence of the attempt.

That's a fascinating way to look at it.

I just found out that Lou Filliger passed away last August. If you spent more than a day on PIX, you would remember him. Strong opinions on just about everything and an incredibly avid hiker. I never got the opportunity to meet him in person and I'm very sad about that. RIP, Lou.

Also, the amendment could have been written to apply differently to different employees by hire date, if preferred. So it could have said that it was only applicable to all those hired on or after 1/1/21, for example.

Not sure you two are saying the same things.