Bill Presson

BG, As Luke says, the relief would have to come from Congress and who knows what they will do. Nevin posted an article today that there's a bill introduced to temporarily increase the DC contribution limits, so it seems everything is in the mix. WCP

Not sure there are exact guidelines. But during a webinar that Brian Graff was doing for us last week, I asked him this specific question. He said that the "intent" of the legislation (based on his discussions with the drafters) is that the amounts would be those attributable to that 8 week window and associated with those payrolls. If employers do differently than that, their mileage may vary. WCP

Not yet. ARA has requested it, but nothing authorized. WCP

Okay. Can't help on the deduction question, but sometimes the eligibility isn't accurate.

It's also an issue right now because the IRS center in Ogden isn't open. So depending on when they open back up, there will likely be a backlog. I can't imagine it's not easier just to grant a blanket automatic extension to 10/15/20.

First, are you sure the employee was eligible? What was the eligibility requirement? When was the employee hired?

No one wants to play "guess the right number"? ?

I don't see how someone can legally decide in 2020 to max out deferrals for a prior year.

Agreed.

Ding...ding...ding!

Congratulations! Very happy that y'all have lasted and succeeded.

The plan sponsor elects whether to allow the specific distributions. If a participant is eligible, but the plan hasn't made the election, the participant can still be eligible for the CRD tax treatment, but the participant can't force the plan to do something that isn't part of the plan.

Perfect. Thank you, ma'am.

Missing some info. If the sellers only sold the assets, why is there a new corporation and a new EIN? Doesn't make sense.

Very glad to have this board. Hope everyone is doing well.

I don't see how. And, even if they could, how much do they really think they'll save?

Seems to be the smart move would be to announce 9/22 "based on our current interpretation" and state that "the IRS might provide further clarification at a later date."

That's where we go from free guidance to needing to be hired. We don't work on SIMPLE plans as a general rule. But you need to find someone that does and pay them for their advice.

Here's Robert's response specifically to the RMD question. https://www.asppa-net.org/news/cares-act—optional-or-required-part-3—rmd-waivers For the record I'm not sure I completely agree with him on a blanket basis.

2009-82 isn't the CARES Act, so I'm not worried about that. And Robert is lumping it all together, so I'm not sure it's specific. Haven't seen the ERIC info other than what you posted.

Our interpretation is that all RMDs are waived for 2020 and it is not optional.

You can go to your employer or to an attorney or to the DOL at this point and ask for help. But I don't have a lot of sympathy for someone that goes 5 years and doesn't look at a paycheck or question a w-2 or ask to see a statement or doesn't go online. It's incomprehensible to me to go that long.

I thought he gave you a lot of good information and advice.

Agree with shERPA. Don't care about the ADP testing if we can get TH relief.

Ray, on the service credits, I meant for eligibility as well as vesting. We do have an employee in Mandeville and I work with a big advisor in that area. Don't get there as often as I would like.