NJ Mike

Wherever the auditor wants to put it. Mike

I am not having any problems with the attachments, so far. Very glad to see this topic being added. We use their document and 5500 systems. Mike

Sounds like a merger more than a marriage! Mike

If you have the 2017 Pension Answer Book, A similar question is raised and answered. It is in Section 9.7. Their answer is that according to IRS representatives, the participant is subject to the new graded schedule. There are no references to any codes or regulations. I have attached a copy of the page.. Mike PAB Section 9.7.pdf

Check out the PBGC instructions for counting days: A. Computation of Time; Filing and Issuance Rules (see 29 CFR § 4041.3 and 29 CFR § 4000 Subpart D) In computing any period of time, if you are counting forward, begin counting on the day after the event occurs and count the last day of the period. If you are counting backwards, begin counting on the day before the event occurs and count the first day of the period. If you counted forward and the last day of the period is a weekend or Federal holiday, then the period runs until the next regular business day after the last day of the period. If an event cannot be more than a certain number of days before a certain date and the last day of the period is a weekend or Federal holiday, then the period runs until the next regular business day before the last day of the period. Note: A proposed termination date may be any day, including a Saturday, Sunday or Federal holiday. Example: Suppose you are issuing a notice of intent to terminate. The notice must be issued at least 60 days, but not more than 90 days, before the proposed termination date. Suppose the 60th day before the proposed termination date is a Saturday. Your notice is timely if you issue it on the following Monday even though that is only 58 days before the proposed termination date. Similarly, if the 90th day before the proposed termination date is Monday, July 4, 2011 (a Federal holiday), your notice is timely if you issue it on Friday, July 1, even though that is 93 days before the proposed termination date. Mike

Down to 456! Good luck. Mike

Not sure if this will help or is what you are looking to do. Say you have 4 divided by 17. Screen shows: 0.235294118 Multiply by 1,000. Screen shoes: 235.2941176 Subtract 235. Screen shows .294117647 So now you have more than 10 digits, your answer is 0.235294117647 Mike

Might be reaching here but is there anything in the document regarding a "mistake of fact" or if contributions are conditioned on their deductibility? Mike

Agree with what has been said. I think all the plans we administer that have loans allow a new loan even if there was a defaulted loan. Just make sure the new loan satisfies the additional condition that it must be either repaid through payroll deduction or the plan receives adequate security. See Treasury Regulation 1.72(p), Q & A 19(b)(2). Mike

and the little you have left turns gray. Mike

Yes

I think PPA changed the asset threshold from $100,000 to $250,000 for plan years beginning in 2007. Mike

How about b. Fiscal Plan Year: ending: Last day of February. or b. Fiscal Plan Year: ending: February 28/29. Mike

Can you terminate the salesperson?

I though Pammie57 just wanted to know if the QNEC can also be used to satisfy the Top Heavy required minimum contribution. The answer is yes. From Treas. Reg. 1.416-1: M-18 Q. May qualified nonelective contributions described in section 401(m)(4)(C) be treated as employer contributions for purposes of the minimum contribution or benefit requirement of section 416? A. Yes. This is the case even if the qualified nonelective contributions are taken into account under the actual deferral percentage test of § 1.401(k)-1(b)(2) or under the actual contribution percentage test of § 1.401(m)-1(b). Mike

Has the employer/sponsor been granted an extension of time to file its federal income tax return to a date later than 1/31/2017?

I think the correct limit is $164,054. This is the actuarial equivalent of the age 62 benefit (which is 90% of the dollar limit of $210,000) actuarially reduced to age 60 using the applicable mortality table and 5% interest). AdKu, I think you reduced it using the 7% factors and Belgrath, I think you took 90% of the $178,000 compensation level. The 100% of 3 year average compensation limit is reduced for service less than 10 years, not participation. However, you would have gotten the question correct! Mike

I think the place to start would be to determine the present value of the benefit under the Plan's stated actuarial assumptions. The plan has to have valuations prepared and the present value as of the last valuation date may be able to be obtained from the plan administrator. Also check to see if the participant has that information available on their most recent annual statement of their benefits under the plan.

Does your plan document only allow loans for a hardship? If so, is it for the safe harbor hardship definition?

From the PBGC instructions: The deadline is normally the later of (a) 180 days after the end of the PBGC's 60-day (or extended) review period or (b) if the plan administrator has timely submitted a valid IRS determination letter request, 120 days after receipt of a favorable determination letter. Mike

This prior discussion may be of help: Mike

It means exactly what it says. I know the law, I am an Actuary with over 35 years experience. Knowing the law is important but how you apply it is the issue.

We are the same as you. Once we are aware of a divorce, we use extreme caution in any possible transactions regarding that participant..

Does the participant get to choose which store or sponsor the gift card is from?

Did you look at IRS Notice 98-4, Q& A E-1?