Bill Presson

I think the termination amendment should address it. However, if it didn't then the Plan Administrator has to interpret the documents to make that determination. Finally, I think consistency with how payrolls that crossed the plan year were handled would possibly influence the final decision. If 9/30 was the plan year end, would compensation from 9/19 to 9/30 have been accrued or would all the compensation have been considered earned on 10/2 (similar to which w-2 the comp would show on for a calendar year end).

Sole proprietors have always had a 10/15 filing date and calculations have been done without issue in the past. Not sure I understand the corporate extension to 11/15 that you reference.

Yes. The QACA plan has to be amended to exclude the SCA employees. The SCA plan would exclude everyone except the SCA employees.

Seems like we had a long thread about something very similar to whether the distribution process in an ESOP could be changed. It was in the last year or two. I wonder if this is the same people involved in that thread.

Replace Macallan with Woodford Reserve and we agree.

Define "some"...

Lou S. is correct.

Understood on the disagreement, especially from the insurance companies. But, at least, I have a letter from Jim Holland and they don't. WCP

If too much was contributed, why is there any corrective contribution?

I know there are some disagreements on the taxation of ps money that has been in the plan for more than two years and is used for premiums. But I'm just talking about using rollover money and the interplay with the incidental rules. For a participant to get a 1099 on just the taxable term costs, the insurance premiums must pass the incidental tests. Let's just use the "less than 50% of the total contributions" test for these purposes. In this instance the entire amount would be rollovers and (at least initially) there would be no contributions. If there were contributions sufficient to allow the premiums to pass the incidental test, I don't think we would be having this discussion. In 1992, I sent an information request to the service to ask about several of these issues. The specific response related to this is: "Because rollover money is neither a 'contribution' nor a 'forfeiture', no portion of the rollover money is taken into consideration when determining the amount of premiums that may be used to provide an incidental level of insurance coverage." So, I think it's pretty clear in the OP's situation as I understand it, that any money used to pay premiums would violate the incidental tests and would, therefore, be 100% taxable.

Rollover money doesn't count in the incidental tests. So, unless they are making regular contributions, the premiums would be a taxable distribution. It's still kosher, but the agent won't want to follow the tax rules.

I agree with Flyboy. Just wait for the letter that will never arrive.

If all the sources are 100% vested, then you are meeting the "minimum" vesting requirements.

The IRS issued new guidance this spring. https://www.irs.gov/Retirement-Plans/New-Methods-for-Correcting-Elective-Deferral-Errors

It's fine to change the dividend option to have them reduce the premiums. It's not a prohibited option. WCP

Usually, it's the wife in a physician practice that is performing office services for about what the deferral amount would be.

I think you have two options: 1. Amend to 90% 2. Find a new payroll provider As a general rule, we recommend clients keep the maximum at 80 or 90 because of the payroll tax issue.

Couple of things (I'm assuming calendar year): 1. What did they file in 2014? 2. How many participants will the plan have on January 1, 2015? Since it's likely an entry date, you can't just say 102, though it's possible.

Additional info and I know how to fix it even though I don't know why it's doing it. So I have my laptop set up on my left and then a large screen directly in front. I've got the monitor set as "extended" and I use the right screen to view virtually everything. My browser is maximized. If I hit the "window" button in the top right to take it out of maximize status, scrolling works even if I go back to maximize. Weird.

Even if the computer system allows it to be filed, the DOL can still reject the filing. I think it's a risk, but I guess you can try. What the CPA is suggesting used to be done often prior to electronic filing. I would be more likely to just not file and do a DFVC later.

Thanks. I shutdown my computer every night, so I don't think it's that. But I'll keep looking. WCP

I love being able to click the little button/bullet and go directly to the first unread message in a thread instead of having to scroll through all the ones I've already read. However, about a week ago (or so), I noticed that when I do that, I can only read whatever message shows up on the screen in the thread. There is no ability to scroll down through the rest of the thread. I've tried using the keyboard page down and arrow keys. I also tried the scroll button on the mouse and "grabbing" the scroll bar on the right side of the screen. Anyone else??

Mike, George said the death benefit isn't an asset until paid by the insurance company. Am I misunderstanding your answer? WCP

Thanks, GMK. That was the item I was missing.

https://epic.org/privacy/rfpa See if that gives you anything. PS: no idea how to post a link on here anymore. Glad that was a short one so I typed it. I've tried to use the "link" icon on the menu several times, but I'm not smart enough to figure it out anymore.