Medusa

Different conclusion reached in following topic: Fidelity Bond Discussion

It can be reported as taxable to either the deceased participant, or to the participant's estate. Not to the beneficiaries.

We have a husband and wife DB plan (not PBGC covered). The husband just died. Currently plan assets are about $330,000, and the following benefit liabilities exist: Death Benefit payable to wife: $425,000 (of which about 1/3 represents the required survivor benefit) Retirement benefit payable to wife: $125,000 The last AFTAP put us at about 73%. The business can't continue without the husband. Obviously we do not have enough assets to pay both the death benefit and the retirement benefit. Everyone would like to get rid of this plan as soon as possible. Any thoughts as to whether there is any way under the sun to accomplish?? All suggestions appreciated!

Our problem is that we made the switch from Relius to ASC forms software and ASC does not have their forms or software for PBGC ready yet. Not having 100% confidence that they will have them in adequate time for us to get everything done, we decided to start using pure My PAA submissions. If we get a pleasant surprise from ASC, so much the better!

It must!!

Man, carrots, I would like to know how you did that. We are having one heck of a time and I am wondering if we are doing something wrong. It simply will not let us submit without that Plan Administrator e-signature. Are you uploading the filing from vendor software, or entering the info directly into My PAA? Any suggestions you have much appreciated!

I purchased them and I can't say they were all that useful. In fact, whenever the subject matter became complex, he would tell you to read further in the ERISA Outline Book. It was useful, but maybe more as a review than as a primary study resource.

Carrots, As far as I can tell, My PAA won't let us submit the filing at all without the Plan Administrator's electronic signature. I don't know if this is a change or not! I do know I don't like it!

Thanks for your reply Tammy. We seem to have some clients who are "technologically challenged".

Is anyone else using "My PAA" through the PBGC's website to e-file Form 1? We are trying to use it for the first time, since the PBGC forms are not yet available on ASC's forms package. We are trying to figure out how we want to deal with the "Plan Administrator's" signature on the e-filing. I would be curious as to whether TPA's are signing on behalf of their clients, or whether they are forwarding a link to their client to e-sign directly. Thanks for any input! Med

Not yet!

Help... can anyone point me to anything that indicates whether elective deferrals to a health savings account (HSA) are added back to compensation, to get to 415 compensation for HCE determination? My gut says yes, but I would like something else to say yes as well. Thanks! Med

Thank you. I am not insane. The attraction of retroactive termination is the potential savings of (a) not having to pay for a valuation for the current year and (b) not having to possibly come up with a required contribution for the year. That being said, these would not be the clients who agree to incur the extra expense of applying for a determination letter. Know what I mean? Thanks again, Med

The firm that I work for seems to routinely allow retroactive plan termination dates for defined benefit plans (non-Title IV). For example, they are trying to terminate some now, effective 12/31/08, on the basis that there haven't yet been any 2009 benefit accruals. I say no and am becoming very unpopular. Am I correct that there is simply no basis at all for doing a retroactive plan termination? This is one of those things that I thought everyone knew but now I'm starting to doubt myself.

Hello all, Some of our clients pay their TPA fees directly (we are the TPA), with the exception of distribution fees. If a participant's vested account balance is $500, and the distribution fee is $100, the participant receives $400 and that is what is reported on their 1099R. Now, the investment platforms don't typically break out that $100 in their annual reports. In the foregoing situation, they would show a distribution of $500. The question is whether the $100 fee is a plan expense or a participant expense. I feel that because the participant never sees the money, nor does the taxable amount include the $100, it is really a plan expense and should be reported as such on the Schedule I. Does anyone feel that this doesn't need to be reflected as a plan expense? All points of view welcome! Also posting this on 5500 board. Medusa