Bri

Wow - she actually signed the plan's Trust agreement and wants to avoid her Trustee responsibility? And is she going to be vested in this contribution? (I'm going to defer to the actual lawyers on here but figured we should get all *those* specifics ahead of time.)

That's because there's no corresponding "form" showing the 40,000 rollover contribution INTO the plan. I think your plan of action sounds sounds right. (Imagine someone job-hopping and taking the same rollover account from plan to plan to, say, four companies within the same year. His 1099s will certainly be way higher than his actual balance.)

I think you're on it, except you wouldn't count the D-B money being applied towards the matching formula in the profit sharing rate group tests. (Just the average benefits percentage test) I don't recall when the employer has to declare how much counts as which type between non-elective and match, though. Could depend on the allocation date as defined in the document.

Just wondering, is it reasonable to charge anyone for an electronic copy of the document, assuming the recipient is okay with that in lieu of paper? Even if it's the two minutes to find it on a corporate server and type out the email address, "here you go", and click Send.

Now you can find all 76 returns using code 4P. Fewer than 10 plans a year, one of which definitely seems wrong by its title. Of course, since advisors like to mine these searches for prospects, I'll just say that'd be a *very* targeted marketing campaign.

actually, my bad, it's explicit in the title of the post, now that I look back up the screen.....

Good point - whatever amount he might elect as the ER portion just reduces the net income he could defer from.

Does it matter if it's not a terminating plan?

Well, it depends on the nature of the 25k. (Schedule C number before SE taxes, versus a number on a W-2 paid by a corporation) Because it's not impossible for the catch-ups and the employer contribution to push his total over the 100% of pay annual additions limit.

(Send the IRS just one of the five dogs at the poker table.)

Sounds right. (And I think you're okay on the second point - the plan would still only cover the owner and spouse.)

The American Miners Act dropped the permitted in-service age for pension plans to 59½, but yes, it has to say that in your document.

I believe that's a yes.

My favorite way to find the table is to Google "new uniform lifetime table", and then switch to the Images part of the results.

I think if you issue the 1099-R for 2021 and show the uncashed check as corresponding asset/liability on the BOY 2022, then the participant no longer is part of the 2022 count. If you're not showing the assets netting to zero, then the person's still a participant and should get his 1099 for 2022 instead of 2021. I suppose.

If they're getting a 2021 1099-R for the as-yet uncashed check I wouldn't consider to count them as 1/1/22 participants. My innate sense of consistency, more than anything else.

On the bright side, I'd think that final 5500 should show 0 participants even at BOY, and with BOY assets/liabilities netting to zero, while EOY assets/liabilities being actual zeroes.

I just thought of one - once your balance goes over the forceout limit (of 3,500!) you can never be forced out later even if your balance/PVAB drops below the threshold.

I would suspect they'd have to re-sign updated pages with 2022 as the effective date, and double-check that they didn't inadvertently have any changed provisions that needed a 12/31/21 signature date. And yet, if this were a brand new plan (absent salary deferrals) it would be fine, right? Hmmmm......

How about, partnership match amounts count as deferrals?

I'm imagining Derrin Watson singing that as lyrics - got a melody for it?

Loved that one, my first pension job had my prior, non-pension, employer as a client so I got to see myself aggregated with my dad as an HCE (even though I maybe earned 15k) in the ADP/ACP tests!

Happened to walk by my old DC-2 study guide and saw those words flip by and wondered if I remembered what it meant. Luckily yes. Anyone got any favorite no-longer-rules they miss? 415(e) perhaps?

I thought I saw something that the 4R isn't yet required for another year, too. But I would suggest considering whether the participant is making one election (I want exactly my RMD amount every year starting now) versus the ad hoc (gotta italicize the Latin!) way that I too am more used to seeing.

And why wouldn't you want to hire Americans to do American work?