Bri

I was short a few the last time I renewed, they told me just to make it up in the next cycle, so I think I ended up with like 40 hours just in calendar 2022 or something like that.

The amount of annuity room "used up" in the conversion is done at the 415 rates, not the 417 rates. Otherwise someone could bifurcate and suggest they get the lump sum for an annuity portion (calculating under 417 to the same number as the full 415 limit would have) and then also expect an annuity stream for the difference.

The SMM might technically only need to go to the one person let in early, but as a part of the full plan document, a very ambitious employee could of course request access to it. (Likely? No, until it happens.)

Well that's a fantastic "out" for your situation, then!

Although you have a uniform formula, it's based on a "non-compliant for 414(s) purposes" definition of pay. The usual parallel would be with a pro rata PS allocation that fails 414(s), no?

Aren't fees just negative gains in the grand scheme of things? (I'd net them out.)

I'm the type that would say, despite the CPA deducting it, this is the real pay that's supposed to be used for 2024, and then you'll end up with a similar issue when you calculate the plan-pay for 2025 as you'd have to deduct both. If those "what they really should have been" numbers don't give you adverse plan issues (underfunding, running out of deduction room for 2025, revised 415 limits affecting the formula, etc.) then stick with your own calculations? Clearly under audit the IRS would make you re-calculate it to remove the deduction, anyway.

I suppose you have update his net wages for the AAC to not include the deduction - does that flow through to the MRC?

Plan document may also spell out some finer points regarding how the measurement period is defined, at least in terms of whether there's "discretion" for the employer in how it will set its hours-counting procedures (specific to the crossing-plan-years topic)

I'd guess they'd interpret that you get the 7900 plus the specific gain/loss on that 7900 in the last two years. Some intricate trust accounting, perhaps. And probably equivalent to saying it's the 10000 minus the (1500 plus its separate gains)

Should be, especially if these weren't brand new HCEs (like the owner's kid, since no pay in the lookback year) getting an accelerated benefit like that.

The second company certainly could become a participating employer to the plan. There'll be arguments for/against separate plans, but it's "easy enough" to do.

The hassle, of course, will arise when either LTPT (long time, part time) employee becomes eligible for deferrals only, and you have to set up the account for him/her.

They owe it to you one way or another, although most sponsors will throw it as plan benefits where possible to avoid running payroll taxes on it. If it's not going to be a match as you're not signing up to do 401(k) from your paychecks, for you they potentially could make it your "profit sharing contributions" for the year. Again, it avoids the related social security/medicare taxes, but you'd get your prevailing wage obligation through the plan that way.

There is, although I don't have a copy myself. It basically parrots the language in question 33a of the EFAST FAQs. Someone here should have a Word version or something readily shareable.

It's listed as 2024 Applicable, 2025 Applicable, etc., with a separate table for each year.

yeah, go to Data Entry -> Tables -> Actuarial -> Annuities Enter your interest rate, your mortality table, and the age range you want and it'll give you a list, looks like this:

Can your recordkeeping software export it? I have a 25-year-old Excel spreadsheet I use for DC cross-testing, and I know I was able to just manually enter the APRs for 8.5%/UP84 (which would almost always prevail for my plans anyway) for all relevant ages off a printout from either Quantech or Pentabs at the time.

If the loans were distributed as a benefit offset, then there's nothing to repay. The plan would have discharged the loans. If they were "only" deemed distributions, then the notes still "exist" and the sponsors could get some tax basis by repaying them with all the accrued interest.

The gateway is a nondiscrimination test on the nonelective contributions they're making, so I suspect you would use the compensation for the period the employee was eligible to receive nonelective contributions. In this case, since the SH entry date is earlier and it's made as a nonelective, that earlier entry date is the relevant starting date for the compensation determination. If they used a SHM then I'd suggest the opposite.

I'd be worried that a true-down is actually a cutback if the calculation and allocation are paired together at the pay period (rather than annual) level.

Of course not, but does the plan document address separate one-off paychecks separately with regard to deferral elections?

Is that an ASC document? I think they have separate QNEC options available, depending on how you filled out that 6D. Something where the BPD allows much more limited QNEC options unless you choose that "special contributions" option in 6D. Coordinate 6-D1's italicized notes with the BPD.

Sounds as though you need a new locator to find the old locator service!

I suppose unless there's a mandatory payout limit in the plan, there's no reason they can't stay await direction from the participant/beneficiary.