Bri

Any way it could be amended either going forward or retroactively to have it reflect what you or the sponsor actually want? (I did a little Sal skimming and the related Code/Regs. Not immediately obvious.)

Are there other employees for 401(a)(26) purposes, or has it always been just the owner?

Does the plan document address the holdout rule in terms of Years or Breaks in Service? If a Year of Service must be completed, then I'd check how the document defines that term as well (like, do you get credit upon 1000 hours, or do all 12 months have to elapse).

Will it be "all" catchups being Roth, or only those caused by the 402(g) limit? (As opposed to ADP or 415 or plan limit excess....) I'd think perhaps they'd let everyone get their first 20,500 in on a pre-tax basis.

And employed on 12/31 doesn't require "employed at 11:59:59 PM", such as if they only worked until 2 pm, flipped off the boss, and started partying early.

Did she freeze the benefit AT her 415 limit? Could the plan allow for excess assets to be reallocated to the participant up to her DB 415 limit first?

I thought the consensus was that -11g amendments could be used even without any sort of failure.

The 7-year rule outlines how long the amounts can take to then be allocated (ratably) under the QRP. So with a 1-person plan, you could estimate looking at having a cap of around 420,000 since you wouldn't be able to use up anything further by the deadline. But it's not a maximum specific dollar amount under a statute.

(The title of the post, rather than the text of the question, specified it's a 401(k) plan rather than a pension.)

The potential 10% penalty tax if he's under 55 and can't roll in the amount by his tax deadline.

Sure - many plans allow loan balances to be rolled over, even if they become due and payable upon termination of employment upon a separation from service with the plan sponsor. (And yeah - definitely make sure the buyer and its plan are cool with accepting such a rollover and can arrange for a new payroll deduction agreement, etc.)

I had a 3-week turnaround back in January for a new plan, but then a February submission is still in their pile.

You would want an amendment to indicate contributions would not be permitted going forward, and a Summary of Material Modifications. At least there's no 204(h) notice, but of course the employees should find out the easy way rather than the hard way that there's nothing else coming out of their paychecks.

Hmmm - we're actually still standalone. I suspected it might be more time consuming to look up how to get Crystal to compute the APRs on the fly, which is why I went with a cheap list of "if age = 68, divide by..... else if age = 69, divide by.... etc." Does that Crystal report from Relius do the interest AND mortality calculation internally? The financial functions only seem to do interest. I'm just imagining trying to link the mortality table values and doing some recursive algorithms from AA through age 120 would require my pay grade to be increased substantially!

Austin, I was actually off BL later Friday, trying to create a bunch of if-then statements in a Crystal report to define the APRs for ages from like 67-90 in order to get custom Relius reports to do the divide the rates into the Sum({rpteeacct.endbalamt},{rptee.ssnum}) field.

Data entry -> Tables -> Actuarial -> Table Entry When the window comes up, choose "table type" of Mortality, and then scroll through your list of Available Tables. CBZ's spreadsheet still had the 2021 mortality table in there.

And of course, it's easier to justify something less than 0.5 if there aren't HCEs getting 10% for themselves.

That looks right, the unisex table on the far right (spot-check matches what I have in Relius)

ooh, right, sorry - misread the year in question. (Was dealing with reaction from booster shot)

The IRS usually puts it in a PDF, which isn't great, but if you don't already have software with it preloaded, a search for "YYYY applicable mortality table" should do the trick.

I agree, it might be tough to pass the blink test such that it's not abusive.

https://fred.stlouisfed.org/series/DGS10

(I'm curious if anyone else issues with the "this feels like dirty pool" tactic of spiking known-unvested terminated employees' allocations. It's not really the same as doing an -11g amendment, because the plan already allowed for the allocations, but boy it kinda smells the same. Does anyone have experience with IRS examinations of this kind of fact pattern, where the employees were eligible but the sponsors knew darned well it was almost an abusive free pass on the testing....)

I found a daily update to the 10-year CMT rate on what seems to be the St. Louis branch of the Fed's website. But yeah, you'd update the applicable mortality table annually, and pull the CMT rate as of the first of each month as appropriate, and a spreadsheet can do the calculations.

Doesn't the rule of parity require a minimum of 5 years? In which case, by the time you know you could exclude the years, the 5th anniversary has already kicked in anyway? I did enjoy thinking about a "Narnia closet" for those excludable years, though.