FAPInJax

I believe the answer is not necessarily. Imagine a DC plan where he becomes eligible on 1/1 to make deferrals but his profit sharing is based on participation compensation from 7/1. Testing is performed on full compensation in that case. I trust someone will enhance or correct this if my interpretation is off.

Oops!! I missed that it was an EZ.

I believe the other point that you alluded to - the forms must be filed electronically. They can not be printed / filled in / mailed in.

No additional accrual of benefits (just a difference in age of valuation). 1,000 at 65 is worth 1075 at 66. I will take my license plate ACT2-AIRE <GGG>

You might have a coverage issue depending on the number of employees who are now excluded due to the freeze and the number of participants in the plan. That is the only thing I can think of.

You are correct. A grandfathered benefit would be necessary.

Do vegetarians eat animal crackers? Why are there interstates in Hawaii? Why do you say your alarm went off when it actually turned on? I've got a million of em!!!!!!!!

Doesn't this have the same downside as current DC plans? It appears the participant is being made 'responsible' for their retirement through their choice of investment. Their lack of investment knowledge could have had a participant close to retirement having their 'shares' greatly decreased during this last market downturn.

The premium has no bearing on the deduction under PPA. The valuation will presumably value a pre-retirement death benefit (which is a complex calculation after the final regulations) and this cost will be part of the minimum required contribution. This extra cost is usually substantially less the premium paid.

Let's start with the basic premise (usually not followed) that the client should make the contribution to the trust and then pay the insurance premiums from the trust. This methodology answers all your questions as they are physically 'employer contributions'. Now, making premium payments directly should be treated exactly as above and therefore all the rules still apply.

You might want to consider having your client institute a 'hard freeze' by amendment to avoid the extra cost. Once they get the existing benefits adequately funded a decision can be made as to what additional benefits will be funded.

Just attended the ACOPA symposium and this was a hot topic. Just filing in the blanks would not require the identification BUT IF there is some thought process that the person has to go through to determine how to answer a particular question then it is. The suggestion was that anyone and everyone should get a PTIN as soon as possible (I believe they are going to be made available in September). Once they come out with the exam (which may be specific to 5500 filing) in 2011 it will be more difficult.

Thanks for the assistance!!

The problem with the PDFs is that often there is a password or even if not some protection enabled. This will make the filing unpalatable to EFAST. Please look at other links with respect to this (sorry but I do not remember the link or I would include it - one was really good because they found that a setting on the PDF triggered the rejection even though a password was not used).

Looks like quarterly allocations of 10,000. I do not believe there is any prohibition against having more than 1 allocation a year (similar to a DC plan).

Unfortunately, the document is not something that can be published. It is coming from the entity that is doing EFAST and would only be released to software vendors (who are not permitted legally to release it). I would suggest that ASPPA (through ACOPA) petition to have them release this document for public consumption.

Well, my reaction is that the problem is with the government. The IRS approved a lookback for the full yield curve (note that it was not in the original law which may explain the EFAST problem). I will see if the checks can be published. I believe it is a 1400 page document and is not really in English.

Here is the government check: Edit tests: B-690SB Schedule SB, Line 21b should be blank when Line 21a (N/A, full yield curve used) is checked.

Relius creates an XML file with the Schedule SB data. Certain items which can not be obtained from the software are required to be entered by the user but much of the data is there. Additional information will be included in future releases.

Enter the prior year interest rate. Right click on the interest calculated and select to do an override of zero. The error should disappear.

I agree that question 20 should permit blanks (although it is possible that EFAST in their infinite wisdom expects 0 - the message goes away when entered as a zero). I do not know about question 34. Question 22 mandates an attachment for the weighted average retirement age. You may scroll past the form itself and find the attachment or actually attach a PDF / text file. This is a difference that it appears we are going to have to live with.

The reply from the Relius GF personnel is as follows: The ability to export the data out of RGF into the IFILE XML format will be available in SP4 which is currently scheduled for 6.11.

Version 16.0 is expected to be mid-September. I would place a call to the Relius Technology group and they can assist you with the decision to upgrade / new computers / operating system / etc.

I believe it requires the use of a special run setting. The website indicates it will be fully supported at Version 16.0.

The plan could have the maximum benefit and provide for the owner to receive a suspension of benefits notice. This basically says that you will receive the benefit from the formula without AE increases. I believe the only issue is that at 70 1/2 the notice is no longer applicable and all the increases trigger. (He needs to be out of the plan <GGG>)