rcline46

Also, your document has to be amended to be a MEP. In my opinion, since each employer is tested separately in a MEP, I would do the look back for each one separately.

What, you want to keep the forfeitures in suspense? No way, the IRS says you must allocate or spend them at the end of each plan year.

Only if he is your primary beneficiary.

Something like pre-1983 this was acceptable.

Yeah, 70 1/2 just seemed like a propitious time to leave. Thank you all for the good wishes.

As of May 1st, 2017, my status will be RETIRED. And many will say it's about time. It has been a looooong fun run folks.

Remember a SEPP is really a SEP-IRA, and you have answered your own question.

I would carefully read what the basic document says about the match, and various documents do describe 'discretionary' differently.

My opinion, employer eats the premiums, deducts the premiums, and everyone moves forward.

Controlled group, 2 companies, new comparability plan. Must use component plans (restructuring) to pass a4 testing. So far so good - oops gateway rears up and says you must give me to those involved in the cross-testing. In the cross-tested, restructured plan, those who are in the OTHER plan are treated as if their contribution is zero - therefore no gate way. In the OTHER plan, testing on a contributions basis, there is no need for gateway. So is this true - we can avoid giving some people only their real contribution and not the gateway.

How about the challenger presenting their support first? Why should we be always on the defensive?

What 5330 and what 15%? Those apply to missed deferrals, not matching contributions. If they were Safe Harbor match then they need to be in by June 30th I think.

Be very careful of your document language. I think the Corbel prototype and volume submitter would need an amendment.

Seems to be a typical Common Paymaster set up, not a PEO or anything like that. For me, everything is fine.

Second owner gets a benefit of $1.00 per month at retirement.

A lot of people who know nothing of the regulations/law are allowed to sell. Many brokers think they can call themselves 'third party administrators' and get away with it

Your plan document will actually have the rules in it for amending vesting service. Follow those rules.

They have more than 100 participants, and so the extended (original) deadline is in place, bolstered by when it was deposited in other months., and if a good reason the 15th of the following month (business days) may be appropriate. No reporting, no DFVCP, no late interest. Don't panic until I say so (GG).

Make sure the employees have at least 30 days to make deferral changes. IE allowing changes only on January 1st is not enuf time.

Bad platform! They should be able to amend the plan and make any system changes between now and 12/31. Put more pressure on them, up to and including terminating services

403(b)???? no exclusions allowed in this case. Either don't allow person to get 1,000 hours or suck it up.

your document controls what definition you may use for any of the tests. It may limit you to the one used to determine that piece of contribution, or it allow you to use any definition that satisfies 414(s).

Any time you do not use one of the compensation safe harbor rules then you need to run the 414(s) test. It does not matter for what portion you exclude for - deferral, non-elective, match, QNEC, QMAC, safe harbor....

A 'Solo k' is a real, full blown, qualified plan with limited testing due to limited participation. You should be treating it just as you would any 401K/profit sharing plan.

Catchup 'happens'. One does NOT sign up for catchups. In your case khn, if someone who signed up for catchup terminates before deferring $18,000 in total, what do you do with the supposed catchup? unless you have a limit, if that person deferred $9,000 and elected an additional $3,000 for catch up, then the testing is for $12,000 and no catchup. After all these years I find it surprising that payrolls are still separating catchup because that is a testing issue, not a payroll issue.