R. Butler

I download into the term date field & then manually enter into the status date. I had never notice that I had the option to not have dates overwritten. I will look for that. It will be a hassle, but it will make mistakes less likely. Thanks for the suggestions.

The other view would argue that after the refund you have a passing test, thus you could shift.

My problem is that in most cases they're entering new term dates, so the old term date is also being overwritten. Its a restaurant so turnover is fairly high & 10-15 rehires a year isn't unusual.

Is there anyway to be warned of duplicat personal information in a DCM import. We've got a few plans that never enter rehires as a rehire, but rather a new hire. If I enter census info. by hand I will get a warning if duplicate information is on the system; thus I know the rehires. If I use the DCM import, I don't get that warning, is there anyway to get that warning using DCM? I've pretty much given up on the client to enter rehires correctly & they have several rehires each year so it is difficult to catch everyone. Thanks in advance for any guidance.

Too aggressive for me, but I've seen that view before.

Received an ASPA ASAP this morning. ASPA essentially supports the Bush proposals, they did make some minor suggestions, most notably expanding the current Saver's credit to cover more people.

I haven't read the newest Bush proposal. I will say that ASPA members got an e-mail within the last week or 2 informing us that this was coming. I don't have the e-mail handy, but as I recall Mr. Graff was under the impression that this latest proposal was tweeked from last years proposal and would be better.

Thanks

Is there any report that shows me Post 88 deferrals. I know I can go into Census & see it, but there are several different funds & it will take me forever to do the math. Thanks for any help.

Thanks for the tip. I found the FAQ. I'm not sure I clearly understood the suggestion, but I was able to use the suggested Census DER to get the result I wanted this year. We shall see how that affects next year at a later date. Thanks again.

Participant Terminates receives a distrib. @ 20% vesting. Forfeits the other 80% at payout. Rehired the same year; works 1,000 hours in the plan year, gets a profit share contrib. but no forfeiture restoration. Obviously the 1,000 hours bumps his vested % to 40%. In calculating the vested balance Relius is including in additional 20% from the forfeited amount. Example: Balance @ 01/01 is $4,000, 20% vested. Payout at 05/01 is $800. Rehired 07/01, works 1,000 hours from 01/01-12/31; gets contrib. of $2,000. At 12/31 participant is 40% vested. Relius says vested balance is $1,600 ($800 of the $2,000 plus an additional 20% on the $4,000 ($800)). Is that correct? At first blush it seems nonsensical that participant would get additional vesting on amounts previously forfeited & not restored.

Thanks, that is very helpful.

Thanks for the cites I knew the Durando case. I couldn't find it on the web; I'll probably have to go to the U.K. law library & copy it. I'll look for that PLR also. I'll tell you I'm running into this argument from other CPAs. Some are adament that this changed with EGTRRA. (Of course they have no basis for that position.) What was more disconcerting, however, is that supposedly a major investment firm with in-house administration has ran an illustration for a prospective client including that pass through income. We may not get that client because the other proposal comes up with better numbers. I tell the prospective client that the better numbers are based on erroneous figures, but really when their CPA also disagrees; it does become difficult. Thanks again for the responses & actually as I was typing this a friend was able to fax me a copy of that Durando case. At least I have a little ammunition now.

Nothing has changed concerning S-Corp. profits & dividends not being treated as plan comp. has it? I have been hammered by several different people this week disagreeging with me on that issue. So much so that I am wondering if I missed something & all of the sudden they count as comp..

Thanks. Creating the 100% vested match account is something I did not consider. I may do that or I may calculate in Excel & import into Relius. I also have considered giving 4000 hours to everyone with deferrals & then requiring 4000 hours for the QMAC. Amazingly I've never used a QMAC in Relius. I am surprised that Relius can't accomodate such a simple allocation formula. Thanks again.

Using Relius 8.3.7. Trying to allocate a QMAC. Relius allocates QMAC pro-rata to compensation. Is there anyway to allocate pro-rata to deferral? Relius support says no, but I'm hoping I got a new or less than stellar analyst.

No. The ACP% in the prior year is 0%

What about it?

DOL Field Assistance Bulletin 2003-3 & DOL Advisory Notice 2001-01A provide recent guidance. There are others.

IRS Reg. §1.401(l)-2(d) for the 5.7%. IRS Notice 98-52 Section VIII.B. for the exclusion of the 3% safe harbor. Now I'm assuming you trying to meet the permitted disparity safe harbor provisions of 401(l). Also, again I'd be surprised if the plan document is not very clear on this issue.

The formula doesn't look permissable to me. The integrated portion cannot exceed the base. The 3% safe harbor cannot be considered in imputing disparity. Thus, unless I don't understand your formula, you cannot have 5.7% on the excess wages & only 5.3% on the pro-rata. The document should be pretty clear on how you allocate the contribution. Most documents I have seen actually take you through the allocation Step by Step.

Agreed. Regardless of the RAP, the fact that a Safe Harbor Notice was likely not given timely would negate safe harbor anyway.

Thanks, I was pretty sure of that, but again it seemed to good to be true, so I just wanted to verify.

I should know this, but.... Safe Harbor 401(k) plan with cross-testing provision . Over 50 participant earns $18,000, defers $16,000, shnec is $540. Assuming gateway is met & nondiscrim. testing passes can participant get a profit sharing allocation of $4,460, bringing total allocations to $21,000? I don't see why not but it seems to good to be true.

Yes, unless it is a new plan or adds a 401(k) provision for the first time during the year.