Bri

Yeah, but that's 2024 if they're smart enough to only count the years after 1/1/2021.

Up to 5.7% of pay up to $0, plus the non-integrated piece. Yup.

I don't think having an EIN for your sole proprietorship prevents you from applying the earnings paid on your 1099 under your SSN. Your Schedule C will have lines for both your SSN and EIN. Which would mean you have no other steps to take regarding the plan sponsorship.

Often though, the "plan B" eligibility provision, the 1000 hours in 12 months, requires the full 12 months to elapse like a traditional Year of Service requirement, so it's possible the guy who hits 1000 hours in month 8 doesn't come in until after the full 12 months elapse. So as CBZ said, definitely check what the doc says to that effect.

Maybe they meant it as plain pro rata and didn't know how to skip the integration question of their document software. Because that's what they end up with basically, right? Up to 5.7% of the first zero of wages. Either that or they have employees with negative earnings (they PAY us to work here!) and therefore are below the integration level. 🤷‍♂️

That's what I'd tell the guy. And they'll be 415-limit catchups so not in any of your testing.

Well, I don't think you need to actually put SH provisions into a one-man plan, but if he wants to burn off the 58,000 of transferred assets, then sure, he can put 6,500 as his deferral election some time in the next week or so.

This IRS website page (blah blah blah not official guidance disclaimer dot dot dot) confirms it: https://www.irs.gov/retirement-plans/deadline-extended-to-add-new-in-plan-roth-rollover-provisions

That's clearly a reference to Bill S. Preston, Esq. there, rather than Mike. 🙂

I think Chapter 10 is dedicated to permitted disparity (it's got to be the shortest chapter along with vesting and 415), and a quick peek does have some illustrations to the calcs.

I'll "fourth" it, just for giggles.

Ha, I'm going to naively say just write to the IRA custodian mentioning the fact pattern and see if they'll do what you tell them! (I suppose in this case, issue the 1099-R only for the taxable gain/loss, since the plan would be issuing the form relating to the 5,000.)

If the person's below the covered comp level, it's the lesser of 1) original EBAR times 2, or 2) original EBAR plus the disparity factor from a big table based on the plan's NRA and the individual's SSRA. If the person's above the covered comp level, it's the lesser of 1) annual accrual / (comp - (50% times covered comp)), or 2) (annual accrual + (disparity factor x covered comp))/ compensation

The thing I always remember is that in your 410b test, you have to test using the lowest eligibility standards, so they've just created some non-benefiting NHCEs who didn't get to start early like our lucky one. However, people like these are generally otherwise excludable, and "probably" don't screw up 410b in general, if you do test separately.

Yes on one, no on two.

Is this a new plan? Could then, perhaps, start the deferral portion as of February 1.

I think that's the way to look at it, you don't double-attribute Grandfather through Father, to Minor.

So I just heard from the enrollment folks at the IRS that they will not grant any CE towards my ERPA renewal, for studying for (and passing) at least one Enrolled Actuary exam during my 2019-2021 enrollment window. Guess I've got to download some recorded sessions this month. Grrrrr...... How is this not legitimate continuing education? What, it's not a "CE program" with an IRS-issued certificate? (If there weren't going to be a delay between my ERPA expiring and being able to apply to the JBEA, I'd just abandon the ERPA credential. EAs get higher ability to represent taxpayers than ERPAs.)

"I don't know why. What did you do with the money after you got the check?"

I think the way it works is that, the grandparent's interest in A isn't attributed to the minor child, since minor child owns less than 50% of A. So minor child isn't owning 100% of company A, just 25%, and you could be in the clear.

Sounds as though they're excess annual additions, rather than either deferrals (402g) or contributions (401k3).

The instructions are pretty clear that a one-participant plan can't file on a 5500-SF, so I suspect they'd counter that no valid filing was done at all. (Kinda like if you try to paper-file when you're not eligible to do anything *but* electronic filing of the EZ.)

Does this argument align with the usual questions over which plan has to refund the over-26 amount? Neither plan is going to have excess deferrals, just the participant. So I'd think in theory the participant can tell either/or what amount has to come out, and if he might be able to leave some in each plan such as to avoid leaving the match hanging as an orphan.

total, regardless of the plan's definition for allocation purposes. 404 cross-references 415(c)(3) for the definition of compensation. (And you get to use full year pay even for partial-year participants.)

Man, that’s brilliant and abusive all in one 😁