mattmc82

The reason all of major ones feel clunky is because they were originally built to the laws in place at that time. Code written in semi dead languages doesn’t really help. It is no surprise no one has a solution for employer roth contributions yet. The nesting nature of most of them is never really all that intuitive so it is difficult to train. Having separate suites for separate functions makes them more accurate but time consuming. Although I will say in my experience it is much better having your 5500 software separate. Too many nuances especially on audited plans where CPAs insist on plopping things in different spaces. Not sure the answer to your question, but I feel like customization is one of the biggest hurdles. Code in the ability to easily override, undo overrides without redoing work and the ability to add notes. The notes should be easily aggregated and easily identified to the portion they apply to. Good luck

Since the new rule with trustee agreements not being pre-approved, I have seen some things I am not accustomed to. Specifically, I have seen documents executed with the only trust agreement being one for a directed trustee So no corporate discretionary trustee and nothing with the employer acknowledging their responsibilities. Perhaps I am just having amnesia since last restatement period, but doesn't there have to be something beyond just a directed trustee?

So I got my first denial in a batch where all the others were approved. I think I discovered why this happened. check the address on the notice versus what is on the 5558 / 5500. my client had a zipcode change that the department of treasury updated that we did not know about. does anyone know if sending a copy of the extension plus proof of timely filing to Internal Revenue Service, Attn: EP Accounts Unit, MS: 6552, Ogden, UT 84201 or fax to 877-792-2864 still works? I cannot get through to the IRS at all.

if a plan is on a PPA document right now, and was merging into a plan that had a cycle 3 document by the end of year, is there any requirement for the plan to do an amendment before merging? I wouldn't think so but curious what the experts here think.

wouldn't you want the HCEs to know they can change their deferrals in the new year? I don't think any of what you out layed is required anymore.

Top-hat plans, gotta love em. I came across this https://www.thompsoncoburn.com/insights/publications/item/2018-11-07/a-top-hat-plan-checklist-for-employers and within they suggest something I had not seen before. Has anyone done this in practice? Our document allows for additional eligibility requirements such as " in order to become an eligible employee, the employee must be approved by the CEO of the plan sponsor". In the past I have just clearly labeled the employee classes that would be eligible (usually officers and a certain level of management). thoughts on this?

thanks all.

is there an employer match? was the definition used by payroll more or less liberal?

So a small employer (1 HCE and 4 HCEs) has a SHM plan. we take over tpa work and discover they are a controlled group with another entity with no plan (1 HCE and 2 NHCEs). the hce is the same person in both scenarios. So now their nice and simple safe harbor plan fails coverage. we can pass coverage using ABT with some QNECs (this option is reserved to be used whenever needed). But, the fail-safe in the document is to add excluded otherwise eligible employees until it passes. Cannot really find anything definitive on whether it is permissible to add a participating employer in this scenario. the qnec to pass abt is the cheaper option but still good to know what the friday morning experts of benefitslink think. thanks

that is how I was leaning. thanks for thinking out loud with me

or maybe it is not an opinion as often times someone here knows something to be bonafide fact. at any rate this plan has last day and 1000 hour for PS allocation. not passing coverage so it says to add those still employed but under 1000 first, then to those with "greatest amount of service during the Plan Year before terminating" and similarly situated employees will be treated the same. so need to add one EE out of those terminated to pass coverage. there are two options terminated employee A - terminated 09/28/2020 with 200 hours terminated employee B - terminated 9/15/2020 with 480 hours which employee from above has the "greatest amount of service"? I could make an argument for A, B or for both being "similarly situated" since service conditions are based on both time and hours. thoughts?

With major recordkeepers announcing their PEP products this is going to be an instant question early on. if a stand alone safe harbor plan wants to join a PEP, do you see any issue with that plan converting into the PEP and keeping safe harbor status (for as long as all provisions are identical)? I know in the past i have heard of some payroll providers not really cooperating with these types of moves as well, requiring the plan to change providers prior to coverting. thoughts?

it is considered late since that is one you cant even extend. that is due 7/31 no matter what

Thanks Larry. So you are saying you would have effective date 1/1/12 AND “first return/report” marked, correct?

Plan X (PN 001) was effective 1/1/2012 and was made up of two entities (A and B) in a controlled group. During 2020, Company B is sold to unrelated buyer. Will spinoff / restate as of 12/31/2020 as Plan Y. Will the plan number for Plan Y have to be 002 or is 001 okay? Original effective date is 1/1/12, so for the "new" spun off plan, this is not considered a "first return/report", correct? Would Line 4 (of the 5500-SF) be completed with the info of Plan X on Plan Y's 2020 return?