AndyH

Janet was right about the first year issue. This problem occurs mostly in the first year. I have seen it several times recently; clients seem to be changing auditors more frequently it seems; with good reason as well. I have gotten them to back down before and limit the calcs to recent. This one says no and it just happens to be the largest and most time consuming to deal with. When they get new clients, do they check 20 years of prior accounting records?

Uggghhh. :angry: Thanks for the input. I will yell less loudly now.

(To WDIK) Now, if I were Harwood or Willy ....... But, I do agree.

Old client - new auditor - large plan Auditor wants to see 10% of retiree original calcs and forms - many going back 20+ years. Auditor says they must select from those receiving payments - not necessarily processed during audit year. Considering IRS statute of limitations and PBGC record retention, this seems abusive. Is this is a reasonable request to audit calcs done 20+ years ago? Are there any relevant auditing standards here?

I've looked at only a couple of them. One I looked at seemed ok to me. Then I learned later that there were several fatal flaws in it from the IRS' perspective. What I learned is that you need to completely understand the IRS' issues with these to be able to "review the document" competently. John, I would engage an attorney who defends advocates of these to truly get an assessment. There are some who advertise here. There are also sellers of these things here who might be able to refer their attorney.

In the yacht club parking lot silly.

Agreed. Good idea. Now get thee to the rolling rally!

I agree, as far as pension administration is concerned, but the last time I looked at this I was concerned about some general rule about these contributions not being allowed to offset another benefit. I'm not sure how that should be interpreted but I would consider it an open issue. These contributions are in lieu of pay, so why should pay justify benefit disparity? Just a tired post-Series rambling.

Brilliant!

Yes, but the document would need to allow for different allocations for different people. Some do. Some do not. You need to follow the terms of the document. But, can it be done? Yes.

Effen, remember, the Red Sox were that little sister for a very long time. Now she has grown a bit, lifts weights, works lots of jobs, and made a few bucks in hedge funds. Here's a vote for a salary cap - effective next year - with some 411(d)(6) protection.

Good one Sully. Janet, I know they are impressive, but I doubt the Red Sox will score 55 runs on Saturday.

Since we're in the humor column, how about some suggestions about who should throw out the first ball in Colorado?

How many of our line drives will be "elevated" to home runs up there? Do double play grounders by grossly overpaid right fielders turn into hits out there? Can really fast fill-in previously-benched center fielders take 3 bases on wild pitches up there instead of 2? Do goofy left fielders who like to retreive balls and then spin and throw without looking get a couple of extra unexpected rotations? Think Manny-top. I'm looking forward to climate issues.

And for those not sleep deprivated by baseball, there is a matter of a football game Thursday night that some of us BC alum with "Flutie for Heisman" hats on our shelves cannot miss.

I would include it. I posted the same question a few years ago and the responses if I recall correctly were to take the safe route and include it (use the gross amount). Unless of course it changes the result. Maybe Tom would have a more "correct" answer but I think he is singing for the next couple of days in DC.

How would this work for a new Cash Balance plan? The plan's deduction limit would be 100% of EOY CL on a sex distinct basis (perhaps) which could be more or less than 100% on a plan-rate (unisex) basis? Or does it depend upon the segments? This seems weird.

My reply to said CPA, at least on a Friday afternoon shortly after 10/15, would be "What's the frequency, Kenneth?"

It would be 150% of the accrued benefit liability, where the accrued benefit liability is limited by 415, so you could think of it as 15% of the dollar limit, if the dollar limit applies.

What is is like for Indian fans knowing that batters 6 and 9 are automatic outs, and batters 7 and 8 are real close? And that the one guy who could change things (a real Indian, BTW-Navajo I believe) is on the bench?

I was referring to the "modified general test". I think the cite is 1.401(a)(4)-8©(3)(iii)©. I don't pretend to be fluent in it; I just know that it is there and there are multiple references to standard interest rates.

True, for a general tested CB plan alone. But if you are doing the abbreviated general test in the a(4) regs wouldn't you be using a standard rate to create the allocation rate? Ditto for 401(a)(26), at least that is how I have seen it done. (But now I'm wondering why). And, if there is a DB/DC combo the standard rates would come into play for such things as the gateway.

No, testing is based upon the "standard" interest and mortality factors contained in 1.401(a)(4) and the segmented rates are out of the "standard" range. Ha Ha.

Because J.D. "Nancy" Drew is batting 6th while potentially our best player, Jacoby Ellsbury, sits on the bench, waiting to replace Manny for defensive purposes.

Good point Mike. Anybody willing to tangle with an extension of this to the maximum? Just extending this discussion a bit, if the DC is 6% then the deduction limit is Greater of: 6% plus 150% of projected unfunded CL or DB maximum under 404 plus 6%. But if the DC is 7% then the deduction limit is Greater of 6% plus 100% of projected unfunded CL or DB maximum under 404 plus 6%. Right? And in 2008, does the new CL replace the old CL and the DB 404 go away?