Bill Presson

The list of characteristic codes that I look at says: "3H Plan sponsor(s) is (are) a member(s) of a controlled group under Code section 414(b) or (c) or of an affiliated service group under section 414(m)."

Don’t you have to test this match formula for effective availability when you have a match that increases as the deferral amount goes up?

Penchecks Trust

I assume this is the letter for the PPA document and it’s possible they missed the C3 restatement.

Here’s an IRS site that says SEP money doesn’t count for filing 5500EZ. https://www.irs.gov/retirement-plans/financial-advisors-are-assets-in-your-clients-one-participant-plans-more-than-250000

Kenneth is correct. The SEP assets are in an IRA and dont count as qualified plan assets. Just don’t put any more money in the SEP either.

If they aren’t HCEs or Key, I don’t see any testing issues.

Any chance the plan has the flexibility to do a 3% profit sharing for individual groups at the employers discretion?

Were they rolled over or merged into the plan?

Peter, I don’t know the answer but based on the facts that you’ve outlined, I wouldn’t spend 10 minutes worrying about it. I would include the ACA and set the default at 10% and move on with my life.

Absolutely.

I would prefer the deposits happen concurrent with the paycheck. But pre funding contributions happens and, as long as it doesn’t affect the year in which the dollars are deducted, is wholly irrelevant in an owner only plan.

An owner can pay himself on whatever schedule he desires.

And understand that a freeze doesn’t mean there won’t be any contribution due. It will still depend on the investments and overall funding level.

1099 is for the year in which the distribution occurs. He’ll get two distributions in 2025. One or two 1099s depending on how y’all produce them. Age used for the 2024 RMD paid by 4/1/25 is the 2024 age.

@Peter Gulia tagging him so he's more likely to see this.

Every plan document I've ever seen outlines what happens if there is no beneficiary. So, the Plan Administrator would follow that guidance and pay whomever it states to pay. Where it goes from there is likely covered by other laws and regulations.

Did they buy the stock or assets of the acquired company?

Without researching, didn’t this get expanded during the COVID shutdown and people accepted this for multiple years?

So it was a wire and not a check? This is odd and, while I believe you are saying what you have been told, I don’t believe “did not inform the plan sponsor of any issues/delays” at all. The sponsor is not being upfront OR their spam filter is too tight.

Why are you having to cross test an integrated profit sharing allocation?

The first computer I used in the workforce after graduating college in 1983 was a Wang (maybe a 2200) with an 8" floppy drive that we used to save some Basic programs we wrote to show some illustrations to clients. Fun stuff.

Wonder if I have a copy of Foxbase sitting around? Have you upgraded to the 3.5 inch diskettes? I think there’s 23 of them. 😇

I’m very confused by your dates. They enter the plan in June 2024. They work 1000 hours in calendar/plan year 2024. Why is the 2024 match getting deposited in January 2026?

Jak, I'm not an IRA expert by any means. However, if the beneficiary inherits the IRA and pays all the taxes, it's just after-tax cash at that point, right? How would they contribute to a Roth other than by the regular contribution rules. There's no "rollover" to do because it's not an IRA anymore.