Bri

What's the actual deemed distribution date? Anything received after that is basis for later.

I'd say it all goes to suspense, contributions and earnings. Company already contributed it, just mis-allocated it.

It's 155. You either add the 135 from box 1 plus the 401(k), or you take the 140 from box 5 and add the Sub-S health. (disclaimer about there may be other deferrals like 125 plan stuff)

Gotcha - I wouldn't have thought to close the window at a time specifically earlier than those final annuity purchases. But yeah, you don't want someone showing up at the office with LS election paperwork the day you're trying to transfer the funds for the annuities!

Also, are retail stores considered service organizations?

Windows close. With a plan termination, everyone's getting paid out.

I'd think the inclusion of the amount in the calculations may differ in BOY vs. EOY valuations, too.

I'd suspect VCP would be needed for that. (I was thinking outside the box, though - fix the W2s, make the employees whole through payroll, and keep the amounts in the plan as profit sharing allocations, as long as the document allows individual allocation groups....or you do an -11g amendment to conform....AND you still have to pass 410b/401a4. Might be easier to just submit and pay a VCP fee, though.)

So you need to ask them the source of the rollover money.

And it depends on where the rollovers came from. Related or unrelated.....

I've got it as 1989 and later. They're 33 this year, so this and the 34 more years until they turn 67 are the 35 years ending in SSRA.

Looks like it's still $4,488 for people born in 1907.

No - you multiplied 124961 by .062 rather than 115401.48

I think a spinoff would have to preserve the DB or DC nature of the original.

Sounds as though they don't want new deductions for the large salaries? Why not keep the DC as is and actually fund a new DB plan, perhaps...

Of course I was kidding, but if they're teenagers cleaning the office bathrooms on the weekends, it's not expensive to provide a 0.5% accrual to a kid making $2,000 over the summer. Then exclude them from everything else. I wonder what the underlying "scheme" was that made the IRS determine this somehow needed to be codified to prevent abuse. I had to VCP married doctors in separate disciplines, because they had their own SIMPLEs but small children.

Put those minor children to work on the payroll! It's their fault!

It's not impossible to find pre-approved documents for other plan sponsors online. Cash balance plans were recently permitted to be on pre-approved documents, so maybe a search comes up with something at least illustrating the "behind the scenes" language in such a document illustrating how the plan addresses preserving prior benefit levels. Even if it's not exactly what your company will want, it might spell out what that other plan did in such a way your attorneys could construct their product for you.

Just something else to throw out there - did that employer formally adopt the plan, or were they just "swept in" by a standardized prototype? My thought would be to look at the supplemental participation agreement, as well as any plan language governing separate employers (whether related or not).

Lastly - are the hours recorded for payroll purposes, such as with a corporation? You mention partners - if this is a partnership then hours may not be so readily accounted for? A partner might not be onsite but might be still leading/pondering the future of his company from his hospital bed.

Does it count as earned income as opposed to passive income?

Can the Plan Administrator and Trustee adjust the custodian's records to account for payables/receivables among money sources?

I usually see override language to the allocation conditions specifically for those amounts.

I don't mind singular they, but if one is to choose that pronoun, they is going to have to use singular verb forms! Bri am using another such concept here - it's not that I'm referring to myself in the third person, I'm just not using a pronoun for my proper name.

BG5150 - I was referencing the line that the participant is also a plan trustee. We all seem to be doubting that each employee gets to be a trustee like that. If the participant is a capital-T Trustee for realsies and refuses to accept the contribution/set up the account, that's certainly problematic, no? (And might there be other Trustees upon whom the responsibility might fall to set up the account as directed by the employer? I asked about vesting because if she was going to leave while nonvested, they could set up a dummy account to hold the soon-to-be-forfeiture.)