Bill Presson

Might want to consider amending the plan to allow loans. He might be able to get more money and won't have a taxable situation.

A prior discussion:

If the plan actually covers only NHCEs, you are free to do just about anything. If group C isn't deferring, then I would just exclude them. Other than that, I would use a plan with everyone in their own group. You can always "group" them in the way you have above.

Generally welfare filings would include schedules A for policy years that end with or within the plan year. So the last year it's on a 9/30 year end, that schedule A is included. Your next plan year ended 9/30, you would include the 11/30 policy year end schedule A.

Congratulations, Reed!

Here's a good discussion about it from back in the day:

I vote yes. And I vote to find another TPA firm.

Based on what you've posted, I don't think they are eligible but I don't know if we have enough information. Review page 8 of IRS Publication 503. That should help. If not, you may need to contact a benefits attorney.

Generally all of them do, I'm pretty sure. I don't remember seeing one that didn't. Obviously an employer can negotiate anything. I don't know the number, but I would have to think it would need to be pretty large. With all that being said, why would an employer feel it was necessary to eliminate that provision?

My former employer (an accounting firm) had interns all the time. Our plan excluded interns as a class, but obviously brought them in if they worked a year. It was rare for that to happen, but we did have the occasional intern that would work multiple tax or audit seasons and then have to enter the plan. It was looked at a couple of times by the IRS over the 12+ years I was there (and responsible for it's operation) and the intern exclusion was never an issue. YMMV.

Be prepared for push back from the DOL. I don't think they are just going to accept it.

No cite, but I've never seen it offset the match.

It's also possible there was some kind of entity acquisition and prior service credit was granted that the OP doesn't mention or know about.

Sounds like Mass Mutual and the employer need to have a discussion and get on the same page.

I would also be interested in how the 5500 compares to the participant accounts (assuming it's a DC plan).

I have it specifically to be able to have power of attorney for my clients since I'm not an attorney, CPA, enrolled actuary or enrolled agent.

Long thread on this a few months ago:

Have the recordkeeper transfer the money to the QDIA and correct the earnings.

Agreed.

I'm not. But Carol Cochran with ABG Southwest is very familiar. Here's their website: http://www.abgsw.com/ Not sure if she would help, but she's a pretty nice person. Might be worth reaching out. You can see on their website that Tribal Services is one of their specialties. Tell her I said hello.

As long as you're not late in filing the 1099s electronically, it's not really your problem.

There are no regulations that prohibit starting a new 401(k) and merging the two plans. But what are you trying to accomplish with a "solo 401(k)"? Because I think a 401(k) that only has a single employee (assuming the owner) pretty much is a solo 401(k).

John, the confusion is coming from about 95% of people writing that they've discovered a miracle. Search "backdoor roth 401(k)" for a sampling.

Agree 100% with the previous posts.

Agree with kcbirm. I would be curious if anyone can even come up with a scenario where a tax exempt trust/plan would pay a participant's taxes. Edited to add: if the policy is being liquidated and the value distributed, then there isn't a >distribution of insurance". It's just a distribution.