TPApril

Auto enrollment is set to 3%. Participant who had opted out and never deferred is rehired. I can't seem to find this in the Plan Doc. Would they need to opt out again, or would the original opt out still stand? Not sure to what extend number of breaks in service would affect this.

Is there any reason a participant who has been 'temporarily laid off" is eligible for a distribution? I don't know the company's definition of 'temporarily' but he was apparently told he can take a distribution, but I feel like employee is not truly terminated.

Slightly related. Plan sponsor requested the transmission of their contribution on the funding deadline of 9/15. Trust reporting recorded it on 9/16. I'm thinking we can still treat it as having been deposited timely, ie by 9/15?

Good question, but it would seem that EZ's are private in part because they indicate an eoy balance wholly attributable to the owner, which would be the case here.

Beginning of Plan Year had 2 participants, 1 owner, and 1 terminated employee. Terminated employee took a full distribution during the year, so that.. End of the Year has owner only and can now file Form 5500-EZ, except.. Assets are under $250,000. I think better off the plan files 5500-ez anyway but never encountered this situation before.

I'm just curious if anyone has had a 5500-EZ filer who was required to file electronically because they have at least 10 electronic returns (as my understanding effective 1/1/24)? Does the IRS actually check this?

I simply cannot remember my resource as it is a number of years, or maybe it's just the 5500 instructions themselves, but I had understood that the Characteristic Code 4L was for Business Travel Death Benefits and that AD&D uses 4Q for Other Benefits. I'm curious how other professionals record that?

For some reason, a plan has allowed a lower paid participant to contribute Voluntary After Tax instead of as Roth 401(k). Annual contributions are around $1,000. I can't seem to think of a reason why this would be better for the participant. Aside from that, Voluntary After Tax Contributions are not even in the Plan Document, so I'm wondering if it's an oversight and they can be reclassified at the recordkeeper as Roth Contributions.

Thank you very much! To answer your question of why the DOL Calculator was not used - the calculations were performed by the bundled recordkeeper a few years ago, and only recently presented to an outside consultant to have a VFCP prepared for the plan.

I'm curious how much detail EBSA requires on a VFCP application for Lost Earnings? Whereas we have individual amounts that were calculated by the recordkeeper for each period, the recordkeeper will not provide their actual calculation, ie how they calculated it. Per application requirements, is it sufficient to just submit the individual lost earnings amounts that were deposited for each late contribution, or do we need more than that?

One-person plan has annuities in his plan. He has beneficiaries designated for the plan (his children). However the annuity company is asking for a beneficiary for their records. I'm unsure, is the Plan the beneficiary, so that the Plan can receive the proceeds and then distribute the assets upon death? Or do the annuities designate the children specifically since that is who is ultimately getting the proceeds?

In prior year, terminated plan paid out all participants, but apparently there is a remaining forfeiture account that had to do with incorrect contributions to participants (not due to unvested participants). Recordkeeper/TPA was supposed to use that forfeiture account to pay for closing fees. Fast forward 9 months later and that forfeiture account is still sitting in the trust, when the intent was to file a final 5500 for that prior year. Seems like 5500 is to be filed showing zero participants but with a balance, but I just don't know.

New plan being set up. The EIN request was submitted and granted with an old address. Having never been used yet, is it a big deal to just forget the first EIN and get a new one? Or file form 8822b to correct the address?

No 5558 was filed for a calendar year plan. Their corporate taxes were extended and are due 9/15. I've never had a calendar year plan 5500 due on 9/15 but it would seem like that fits the definition of the Automatic Extension?

This is a legacy plan with a set of long time partners. One partner has an LLC investment that pays out dividends, but the K-1 has shown a negative balance for two years now, with the most recent year even more negative. Not sure how to treat this for calculation of total assets in the plan?