Bill Presson

Perfect. Thanks RBG!

It got pushed back. According to this link: https://www.irs.gov/retirement-plans/determination-opinion-and-advisory-letters-6-year-cycle-for-pre-approved-plans the next DC cycle will end 1/31/23 meaning it begins 2/1/21. Someone correct me if I'm wrong. WCP

They're SOL. What they're likely trying to do is get out of paying FICA, etc.

Don't have enough info, but possibly what we call a "true up" contribution after the end of the year.

RBR, I understand that the HCEs don't want refunds. We get that as well. But I tell them (as BG mentioned) that the worst part of getting refunds is that they deferred some taxes until the next year. The worst part of NOT getting refunds is that they left contributions on the table. I tell them that when they get a refund, they know that they deferred the maximum amount they were allowed by law. If they don't get a refund, then they were short. Usually works. It's actually one of the rare times we encourage clients to "prefund" and we have the ability to adjust to the perfect number after the end of the year.

JAA, I asked Ms Ilene to clarify. She was just talking about the credit. Here's her response. Section 45E of the Code (which controls the Credit) says: (1) In general The term "eligible employer" has the meaning given such term by section 408(p)(2)(C)(i). BUT: Section 45E(c)(d)(1)(B) (which discusses the definition of Qualified startup costs) says: (B) Plan must have at least 1 participant Such term shall not include any expense in connection with a plan that does not have at least 1 employee eligible to participate who is not a highly compensated employee. So, while a plan covering just an owner or just HCEs is technically eligible for the credit, there are no expenses that qualify for the credit. This provision was in the law before SECURE. Sorry ….

Austin, we just started with it and I really like it so far. It's going to take some getting used to across the whole firm, but it gives us the options we needed versus using our in house product. You should talk to Ms Katie Boyer. She'll provide the demo. I've got her contact info if you want it. WCP

After tax contributions are always subject to ACP even in a safe harbor plan.

This is our understanding as well. Also, if there is a discretionary match that is intended to automatically satisfy the ACP test, then an annual notice is still required. We have essentially been providing a single SH/QDIA/ETC notice, so I don't think this is really worth fooling with. But it does help if someone forgets to distribute a notice.

It's a maybe. Depends on the exact details of the situation and that likely can't be outlined here. Can it be done? Yes. But it all depends on the plan design.

Here's the actual language. It just substitutes the age and specifically references owners. SEC. 114. Increase in age for required beginning date for mandatory distributions. (a) In general.—Section 401(a)(9)(C)(i)(I) of the Internal Revenue Code of 1986 is amended by striking “age 70½” and inserting “age 72”. (b) Spouse beneficiaries; special rule for owners.—Subparagraphs (B)(iv)(I) and (C)(ii)(I) of section 401(a)(9) of such Code are each amended by striking “age 70½” and inserting “age 72”. (c) Conforming amendments.—The last sentence of section 408(b) of such Code is amended by striking “age 70½” and inserting “age 72”. (d) Effective date.—The amendments made by this section shall apply to distributions required to be made after December 31, 2019, with respect to individuals who attain age 70½ after such date.

That hasn't changed.

It's only for the employer contribution part of any plan. Any participant deferral plan still has to be adopted in advance of the first payroll deduction.

And receive the safe harbor matching because there can't be any hours requirement once the eligibility is met. I know that was implied.

I would recommend this.

Also, is there a way to get more than 1 month prescription at a time? Maybe 3 or 6 months, thus reducing the number of times he might have to submit?

It's an audit per year.

credit doesn't apply if there was a plan in place during the previous three years.

When I first started my TPA in 1986, we used to do it via a sign in sheet, like attendance at a meeting. Did that for a couple of years until I had a client go through an IRS audit. Found out it was complete overkill and haven't done it since.

No. If you are paid for preparing a return, you have to have a PTIN.

Dave, That appears to have worked. Thanks!

This morning when looking at my "unread" message list like I do almost every day, it was automatically showing the expanded view (title and first several lines). I clicked the condensed view to change back, but nothing happened. Not the worst thing in the world, but not sure why it changed and can't be corrected. Thanks. WCP

Nope. You're right. Dang. Hate when I make a mistake. Almost got through the whole year, this time. ?

Can't do the first one either or at least not the full amount.

No. From the IRS: A participant can make catch-up contributions for a year up to the lesser of the following amounts: The catch-up contribution dollar limit, or The excess of the participant's compensation over the elective deferral contributions that are not catch-up contributions.