thepensionmaven

Am I correct in the fact that, if a client has a DB plan as well as a 401(k) that cover the same participants AND each plan satisfies 401(a) on it's own, the answer is "no"? The clint thinks if we answer no, this indicates the plan(s) out of compliance, which would not be the case.

Absolutely.

I usually put myself down as the person to contact and leave my email. Most clients are clueless when it comes to any of this. This way, I get the return receipt. BTW, I found an actual phone number you can call to check whether a plan actually was filed or not if a receipt can not be found. Contrary to what DOL said in the past, DFVC does track and keep a record.

She was a wonderful person and a great instructor. Met her in person when she came to White Plains on her way to see family, I assume before she passed. Looked up the new version, as mentioned. Subscription for $1,000 a bit steep, but thanks for the suggestion. I need to digest the instructions, no one needs an IRS "love letter".

Got it, thanks. There's really no change for my plans, as I always count eligible participants, whether they defer or not.

Please see attached.changes-for-the-2023-form-5500-and-form-5500-sf-annual-return-reports.pdfchanges-for-the-2023-form-5500-and-form-5500-sf-annual-return-reports.pdf OK, page 4, the exactly what is the change? This is a?DOL fact sheet.

For our clients, that sponsor safe harbor matching contributions, Form 5500-SF (2022) included participants, both beginning of year and end of year, that were eligible to contriubte, but in fact, elected not to. For 2023, we count only participants with account balances in 5a and 5b If only counting participants that are contributing, would not 5a and 5b of form 5500-SF be repeated in c(1) and (c2)? Also, obviously the end of year participants on the 2022 includes those who are eligible, how would you reconcile 2022 with 2023 when the end of 2022 and the beginning of 2023 are not the same? Carr the number through to 2023 and make the adjustment there?

Where can I find out more about Mega Backdoor Roth

I believe we filed a DFVC for a client, but did not snapshot each page. Is there any way to check if it was filed and if in fact, did go through? I can't believe they do not have a database.

My ERPA expires 9/30/25, so I'm using 12/31/24, 12/31/ and 12/31/22. I'm 5 credits short.based on medical disability (torn retina, took 5 months to recover) In lieu of that, what happens, I have to wait until I make up those 5 and reapply or am I ***ed until next cycle

Thanks, this will suffice, I think the client is stuck with this as there is no way they want to amend eligibility, which also affect the SHNE and/or go with ET.

Just attempting to finf a way around this. I venture to say the only way at this point, prospectively of course,would be to change from plan year elig to elapsed time, but that means more for those who are more than 500 hours and would need to be included in any employer contribution. When the proposed regs were issued I was told by someone who I thought she knew what she was talking about, that as long as any otherwise eligible employee elected no employee contribution, and had less than 1 year if service, that means the plan is not an LTPT. At this point, I can only assume that individual did not know what she was talking about.

Just trying ti find a way for a plan ti avoid these aggregios rules. I would venture that any If any individual works between 501-1000 hours could afforx to defer and will still be considered an LTPT and therefore be subject. Thesd regs arr for participants thst are eligible and actually do contribute. Suppose the employee dies not contribute, how can abd should be 100% vested in a zero contribution?

Let's suppose an employee meets the 500 hours and completes a Election Form (from the plan) that he/she does not wish to contribute,or submits an Election Form to the trustees that he/she elects to make either a 0% or $0 contribution, but the plan contains the standard 1 year eligibility for employer contributions, would that employee NOT be considered a LTPT employee and therefore, the plan does NOT need to follow the LTPT rule? Of course the employer conttibution rrquirement would still apply as well as any required testing. I do not see anywhere this question has been asked or answered.

My experience has been that some record keepers ask the participant to complete a loan application and send out a check. That’s it. I am proactive in my approach by attempting to ask myself what an auditor will be looking for if the plan is subject to audit. In my role as an ERPA I handle many IRS audits of plans with loans; an auditor of plan with loans has always asked for a loan document, collateral pledge and assignment, as well spousal consent if the loan is over $5000 and of course an amortization schedule Of course, the auditor looks to see that not only is the loan being repaid as well in accordance with the amortization we provide. IMHO, better to be prepared in advance.

As well, with this particular plan, compensation is defined as 415 compensation, w/o adjustment, W22 plus employee compensation. W2 is shown on some of our plans box 1 is net, some box 5 including deferrals. No wonder why so many safe harbor and PS plans are calculated incorrectly.

isn’t the 3% safe harbor based on gross, not net?

I must be having a senior moment here, but let’s say we have an employee with a W-2 of $25,000 and he contributes $23,500 as a deferral, so the net W-2 is $1,500. The accountant is telling me the profit sharing contribution can not be 25% of $25,000! I believe he is confusing the higher wage earner whose max contribution includes the employee elective contribution .

Client returned a signed page 1 for me to file. Will this be accepted??

401(k) is a SHM plan. Employer did not make enough of a matching contribution to cover the total contribution and the corporate tax return has been filed. Can the owner waive a portion of the safe harbor he would have received, , such that he does not have to pay in the additional sum.

We have an overfunded DB the client needs to terminate. There is plenty of room to raise projected and accrued. There are 4-5 vested terms that terminated more than 5 years ago. Question, although possible to recalculate on a new benefit (obviously to reduce the overfunding), since they terminated over 5 years ago and have NOT been paid out anything, is it necessary to recalculate these benefits???

Thanks very much. I did look at this, great program, but I am a mac user and e does not have a Mac version and does not plan to include one .

Absolutely, way too many. Thanks

Client sponsors a standalone profit-sharing plan, family only; six individual accounts with Vanguard. Spouse thinks she know all, saw something online that allows a rollover to Roth IRA, gets husband, over 59-1/2, and plan allows for "in service” to rollover all his Vanguard accounts to individual Roth IRAs, without paying any taxes. To my knowledge you can’t rollover unless taxes paid, but of course, could be wrong.

Thanks, would not the April be based on the 12/31/23 account balance, yet age in 2025;and the second distriubtion due by 12/31/25 based on account value at 12/31/24 at age in 2025 as well?