Bri

Typically the inflation guard rider requires the bond to cover 10% at the time it's purchased, and only then would the increase be in play if needed. (Still waiting for my first claim on their bond.) I used to do 10% of the BOY asset value on the 5500, but I forget the specifics as to why it wouldn't have been the EOY value.

I was wondering why I'd been listed with the gold cup for yesterday when there were at least three other folks with the same 2 "reputation points". Then I refreshed the page and our names were shuffled, so I was then listed with the silver. Refresh again, and listed fourth. Then back to first. I surmise all our profiles say we last "won" the day on May 24th. I had wondered if there were some underlying tiebreaker algorithm in play. Honestly, it's not a vanity thing! 🤪 --bri

Yup, it's still 5% total in the DC

The SH gets forfeited with its earnings. The employee's 1099-R for the refund (should be code E for an EPCRS correction) would determine what year it's taxable. Typically they're taxable in the year they get them back, even if that's a different year from the original deduction shown on their W-2. So maybe they end up taxed at their 2022 marginal rate rather than their 2021 rate.

I'm thinking back to a Relius seminar I went to led by Robert Richter (whose voice is like a friendly version of Belichick!), who mentioned that any -11g amendments typically don't get you the extra deductibility - you have to use the rules of the plan as they were in effect on actual 12/31 (not including anything adopted retroactively). So while the overall dollar amount might be under the 404 cap for the plan, I suppose the hangup is whether or not making a contribution for someone beyond what they would have had in the first place, then becomes a qualifying ordinary business expense like it would be for the original plan layout as of that date.

Does their previously-executed form indicate what employer and plan the election applies to? (Makes a merger more likely to be okay, compared to a new employee at the acquiring entity.)

I think they'd just be on the hook for a THM, then. Whether that's 3 or 5 depends on whether he's in an excluded class of employees, versus just being a participant with a 0% benefit formula on the DB side. If you make him completely ineligible from the DC plan, too, then you owe him nothing, and he still counts in the tests as a zero.

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)