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Bri last won the day on May 24

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  • Birthday 08/03/1971

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  1. I thought it was the opposite - you don't have to offer annuities but if you do then the spouse has to agree to any annuity version that's not the QJSA. Yeah, been a while....
  2. I would think there's one value per person for 414(s) compensation as used in the testing, as it sounds that these plans are being aggregated to pass their stuff. And as such, one value to use to determine the minimum gateway. (happy to be wrong) Participants always enter both plans at the same time, right? (With only the comp definition different?)
  3. 1099-Rs show zero quite often simply as a result of being a corrected form, so I suspect nothing's preventing them from being generated almost "voluntarily"...
  4. I'd suspect not - so there could be multiple decisions to make - a) can the fees eat the balances under the plan's terms, and b) how much is left to pay after *that* and whether a 1099 would be specifically required based on the actual payment value. (And I think the $10 is an aggregate total, not any one individual payment to the person, right?)
  5. Guess it depends on what the document says...
  6. If the employee had a legitimate termination of employment, took a withdrawal upon that distributable event in the year of age 55 or later, and then was later rehired, I would think the withdrawal still was exempt from the 10% because that's determined at the time of the withdrawal, no?
  7. I suppose there's always the opportunity to elect X% of pay not to exceed $Y. Might not really get you what you want but illustrates some flexibility perhaps.
  8. I would at least double-check to see if the BPD says anything about how deferral elections may or may not apply to "imputed income" rather than a straight wage payment to the employee.
  9. Well heck, if we're getting semantic/pedantic, let's go further and say it's the 5th anniversary of the first day of the plan year in which participation commenced.
  10. Or, if it's not too late, allocate a QNEC to last year's NHCEs?
  11. And of course, I overlooked that it's still the 2024 minimum being paid based off 2023, so I do think they're going to have to recoup some of that IRA rollover to satisfy the RMD. (And adjust the amount coming out of the IRA for earnings since it was an ineligible rollover contribution. Hmmm, thinking out loud has me presuming only the "principal" amount coming from the IRA satisfies the RMD for the plan, like you couldn't count some of the earnings towards the RMD.)
  12. If the termination is 12/15/24, isn't the RBD 4/1/2025 so that the 2023 balance is out of the equation?
  13. I like Lou's idea. but wonder...... Is there any thought that because the payroll-period SH match on the commissions would not have been deposited quarterly as is typically required, that somehow the adjustment now also has to include earnings from what would have been those "end of following quarter" deadlines?
  14. Not the ones who roll over their balances. But the exception is for termination of employment, not termination of the plan. 72(t)(2)(A): (v) made to an employee after separation from service after attainment of age 55,
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