Dennis G.

A 125 Plan allows entry date first day of month after meeting eligibility requirements. The 125 Plan is a calendar year plan. If the entry date of the participant is Nov 1, can the participant submit for reimbursement a medical expense incurred in March of the same calendar year?

Hi, Can anyone tell me if the increased loan limits under the CARES Act has been extended past September 27? 2020? Thanks.

As a TPA I'm being asked by a CPA whether paying employees Sick and Family Leave constitutes compensation for purposes of any 401(k) Safe-Harbor contribution. Any thoughts?

As the author of the original post, to clarify, this is a one man plan with all assets attributable to accumulation as a Defined Benefit Plan asset. The 1 man participant took his RMD due him for 2019 before 9/30/2019, plan year end. In October 2019 the plan transferred the remainder of the DB assets to an IRA. Perhaps the better question is did the DB Plan produce an RMD requirement for 2020 because it held assets as of 9/30/2019?

The 1 man plan participant in the DB did take his 2019 RMD prior to 9/30/2019. As I said he rolled the remainder of the DB assets into an IRA in October 2019.

I need some guidance on an RMD for 2020 for a terminated defined benefit pension plan. The plan year end was 9/30/19. As of 9/30/2019 the plan held assets that produced a $100K RMD for 2020. However in October 2019, the plan sponsor (1 man plan) rolled the remainder of the DB assets to his IRA. I know that under CARES DCs and IRAs can waive RMDs for 2020. But what about this situation? Does he need to take the $100K from the IRA to satisfy the RMD requirement for the DB Plan for 2020? I'm sure the CPA will be asking for a reference to the answer. Any help is appreciated.

I have a client who took his RMD in January 2020 for 2020 from his IRA. Due to CARES can he put it back in the IRA now? It has been more than 60 days since he took the RMD. Advice please.

Thanks Belgarath for your comments. Yes I do need some expert advice. Seems like the shares purchased in excess of the amount that can be absorbed by the participants in a contribution allocation would belong to the "buyer", e.g. the Employer. If that is the case how to get those shares back into the plan. Contribute those shares (at what market value?) back to the plan?

The plan holds no cash, only Employer stock. When a participant is eligible for distribution the Employer contributes money to the plan to buy the shares of those participants so that the shares remain in the plan. The total distribution paid in cash from the Employer for the plan year exceeds the dollar amount that can be deducted as a contribution and allocated to participants to buy the shares of the participants who received distribution. There were a number of participants (more than one) who received cash distributions.

The company is entirely owned by the ESOP (all Shares of the company are held in the ESOP) So there are shares "sold" by those that diversified that cannot be allocated without exceeding 415. Does this mean that the share that cannot be allocated are now owned by the Plan Sponsor outside the plan?

I administer an ESOP plan that only holds Employer Shares. When a participant terminates the participant sells his shares to the plan in exchange for cash. The "cash" paid is a cash contribution to the plan and in turn paid out to the terminated participant. The shares "sold" to the plan are allocated to the remaining participants eligible to receive a contribution to the plan for the year. However, because of diversification the value of the shares sold this year exceeds the 415 limit for contribution allocation. What can be done? Does the value of the shares in excess of the 415 limit belong to the Employer Sponsor outside the plan?

Can an employee participating in a Cafeteria Plan FSA also establish and use a HSA?

Maybe this is the wrong place to ask this question, but can a terminated employee who had an FSA account with his former employer use funds in the FSA account to pay the COBRA coverage premium payments?

An IRA holder over age 70 1/2 has taken her RMD from the IRA as required. She subsequently becomes a participant in a 401(k) plan. She is not highly-compensated nor an owner of the plan sponsor, but rather a rank-in-file employee. If she rolls her IRA into the 401(k) plan can she stop taking an RMD on the IRA balance rolled into the 401(k) until she actually retires?

Beyond the annual Certificate of Participation and the periodic Summary Plan Description is there any requirement to provide notice to a participant that they are eligible for a distribution from the plan? Normally the distribution election forms and information are sent to the participant upon termination, retirement, etc. but if the terminated participant does not respond are you required each year to remind the terminated participant of his/her eligibility to receive there benefits?

I'm a TPA with a one participant DB plan. The participant is the plan sponsor, trustee, and participant. He is asking me if he could take part of his plan assets and purchase a property he owns as an individual. On it's face it sounds like a prohibited transaction. Can this be done?

Can reimbursements from a FSA be made over multiple plan years for a service rendered in one plan year? Example: Lasik surgery is performed in 2013 for a fee of $2,400. Can payments be made from the FSA account at $100 per month for plan years 2013 and 2014? Thanks.

I agree that the distribution (from plan assets, not a contribution to the plan) should have been made to the participant (who had reached normal retirement age) and then on to the church as his personal deduction. But my question remains, does this meet the definition of a prohibited transaction and therefore subject to filing form 5330 with related excise taxes? Thanks again.

I'm a TPA working with a self Trusteed Money Purchase Pension Plan plan that made a "donation" to a church from plan assets. The plan is currently a one-man plan. Does this violate the Exclusive Benefit Rule? Is it a Prohibited Transaction reportable on Form 5330? Any help is appreciated.