Bill Presson

If the doctors are each in their own group, can the employer choose to not make a contribution for his group?

Make sure you know exactly how the purchase happened. Buying a business via a stock or entity purchase is very rare, especially in professional practices. Doing it that way causes the buying entity to take on existing liability and most don't want to do that. Now assuming that IS what happened, then the transition rules in 410(b) apply and the census of the purchased entity is ignored for the plan of Dental Practice A. That would include ADP/ACP. But if Dental Practice A just bought the assets, then the employees were likely just hired by A and will be treated like any other employee.

He can if the fee comes out of his account and doesn't reduce his RMD. The RMD is designed to impose taxes on the tax deferred accounts at some point in time. Reducing an RMD defeats that purpose.

I would use the schedule A they provided you and keep that form in the file.

The IRS typically doesn't even deal with cents. Are you sure there aren't some rounding options that would resolve the issue?

Always nice to find old threads on "new" topics. Just had a question from a potential client about this issue. I don't like the idea of a company being the trustee, but need to be able to tell him whether or not they can be. So, it appears that it is based on state law (assuming Peter is correct above and I have no reason to believe otherwise). I did have one client in Kentucky get approval from the Dept of Financial Institutions to do this, but they were working closely with their legal counsel, so I didn't think much about it. Plus it was 20+ years ago when I knew more than I know now! Any suggestions on how to determine whether a state will allow this? Or is it going to mean hiring an attorney in the state to help? Thanks.

It's the same for any plan required to file a 5500. The filing penalties can be extreme especially compared to the relative ease of filing a welfare 5500. As to your second question, we've filed 5500's for plans that include benefits with different policy years. I've never had it questioned by the IRS or DOL as long as we remain consistent.

Agreed.

I think this will actually increase the number of people eligible, though perhaps not participating, in a 401(k). Since, in the retirement world, full time is approximately 20 hours per week, this might indicate a move from two people working about 80 hours per week to three people working about 80 hours per week. Businesses that had been in the 80-95 employee range, might suddenly have 120+ and now have to get an audit. Yuck. I hate thinking about this.

Good question, but I'm afraid I don't know. We use Relius, but never used their web client product. We always just filed directly on the EFAST2 site.

No, they are not. Look at it like this: 1)Assets plus Liabilities = Capital. 2) Therefore, Capital = Assets minus Liabilities I don't think this math works!

The deadline is based on the local time zone where the plan is located. If it was filed a day late last year, you might be okay if you were using the Relius web client. I know that they got a special one day extension for their users.

Antsyness. Yay for new words!

The reason that the incidental limits "do not apply" when you use seasoned money is because the entire transaction is taxable.

The 25% or 50% limit is based on total contributions to the plan, not just the current year. That total does not include rollovers.

When I get employers talking about employees using terms like this, they generally mean employees working less than 30 hours per week because that's how they get excluded from insurance coverage. I always have to explain that qualified plans don't work that way, and I'm betting you get to do that as well.

If the employers are unrelated the $50k limit is based on each employers plan. The $17k deferral limit is an individual limit and you appear to have satisfied that requirement. Based on your info, I don't see an issue.

Keep in mind that cafeteria plans don't actually have a filing requirement; the underlying welfare benefits do.

Ours ranges from 20 to 50 plans depending on the size of the plans in assets, participants & complexity. Very hard to compare numbers from firm to firm. We are a wholly owned affiliate of a CPA firm.

Give the HCE's a pay cut and give them the entire 3% safe harbor.

I thought the DOL gave actuaries the ability to just print their name and initial it. I sign my name because it's less legible!

I thought the DOL gave actuaries the ability to just print their name and initial it.

Yes, you should maintain a nonsafe harbor match source.

Probably only 1 out of 5 of our clients actually received an extension acceptance letter.

Not sure concern is the correct term, but my clients (and others) often express surprise that the 5500 is a public form. I'm not aware of fraud specifically associated with knowing the employer's EIN, but it's used repeatedly in business transactions.