NJ Mike

Are dictators elected?

Are any Key Employees making After Tax Contributions? Or only non-Key employees?

I remember them and yes, top heavy caused their demise.

From the IRS instructions for tje 2015 Form 5500-EZ: You do not have to file Form 5500-EZ for the 2015 plan year for a one-participant plan if the total of the plan's assets and the assets of all other one-participant plans maintained by the employer at the end of the 2015 plan year does not exceed $250,000, unless 2015 is the final plan year of the plan. For more information on final plan years, see Final Return later.

Vlad401k Yes, assuming the same percent of pay contribution to both a 65 year old and 75 year old (assuming both have attained their NRD under the plan provisions) would have different EBARs. In you EBAR calculation, the factor in the denominator is the annuity factor at NRD or if past NRD, at current age. So a 65 year old who has reached their NRD has a different annuity factor than a 75 year old who has attained their NRD and thus the EBARs would be different. Right now, I am also assuming no imputed permitted disparity. Also, accumulation factor is 0. Look at the 410(b)/401(k) worksheet DATAIR supplies and all the relevant numbers are shown. Mike

We also use the DATAIR system for our plans. The EBARs that it is calculating for participants beyond NRD are correct. They are using the annuity factor as of the participant's attained age with 0 years to retirement. You may want to double check your coding of both plan assumptions as well as the participant data just to make sure. If you have not done so, look at the 410(b)/401(a)(4) Worksheet output provided by DATAIR to see the factors used in their calculation. If you feel confident that their calculations are in error, you may want to post the question on DATAIR's message board or contact them directly. I disagree with your thought that the EBAR should stay the same each year after NRD if percentage of compensation stays the same. The annuity factor changes each year and will thus the EBARs will be different.

I didn't think you could do it to meet minimum contribution requirements but ok for amounts in excess of required minimum. But it has been a while since I looked into this.

Bird - Our office made the same decision as yours. So now we are not answering the questions either. However, we are still filling in the preparer information even though that is optional. Mike

Don't know if this helps but for the past few years the Form 5500 and Form 5500-SF instructions have included the following in the line for the participant count: ; For pension benefit plans, "alternate payees" entitled to benefits under a qualified domestic relations order are not to be counted as participants for this line. Not sure how this pertains to Form 5500-EZ but I would think the definition of a participant would be consistent.

We have used FT Williams for the past 3 years. We love it. Excellent service. We left Corbel/Relius after many years mainly due to their high cost to us, a small firm.

The PBGC began requesting this information for Form 501's filed after March 1, 2015. You might want to check out the revised instructions for Form 501 on the PBGC's website.

We have FT Williams for the past 2 years and are very happy with the system. Find it easier and cheaper than Relius.

The form was filed with the Draft Accountant's Opinion. So far, it seems to have been accepted. It is scary that when you view the form on the EFAST site, the Draft opinion is right there for all to see.

We have a client with first year audit requirement who waited to hire auditor. Auditor will not have report completed by 10/15 filing date and wants client to attach the "Draft" copy of report which we received today. Any thoughts?

We have been using Prime +1%.

Also check out Treas. Reg. 1.72(p)-1 Q & A 19(b)(2)

I also like the 5:00 theory. Our standard is if someone works on December 31, we consider them d retired on January 1. By any chance did this person receive Holiday pay for January 1st?

I think the Regs say you can round up, down or nearest al long as it is done in a consistent and nondiscriminatory manner.

We bill on the number of participants but in most of our 401(k) plans, we charge one rate for participants who defer and a lower rate for all others.

My understanding under a defined benefit plan is that the benefit must commence prior to the RBD, which in this case was 4/1/12. The payment interval is established based on the first payment, in this case, annual. This first payment covers the period 4/1/12 to 3/31/13. The second interval is 4/1/13 to 3/31/14 and the annual payment can be made anytime in this period. If that is correc, the payments have been timely made. As far as the value of the lump sum, if the 4/1/14 to 3/31/15 payment has not been made, I would value the $60,000 on the date of distribution and add back in the value of "missed" payments. For example, if paid out on 7/1/14, value the benefit at that date and add back in the value of the 3 payments due (April, May and June).

I had the same problem but I had left Item 7a on Form 5500-SF blank. When I redid putting in "0" for that Item, my problem went away. Mike