J2D2

ttott, I think you've got it!

#2 Midnight Express

#15 Raging Bull?

#12 Gone With The Wind #31 West Side Story

We were involved tangentially in a DOL audit last summer. The DOL auditor rejected our proposal to use the calculator to determine the lost earnings on late contributions.

How about the cone of silence?

Bingo! Oops . . . if I can't vote I probably shouldn't gamble either. Sorry.

Which I believe will state that the eligibility computation period starts with employment commencement date (sorry for the inartful "date of hire" reference).

I vote for date of hire.

Haven't looked at this for awhile, but I think a ruling on ASG status is something that you can include in a determination letter request.

You just might want to discuss this with the union, before you adopt the amendment. Unions are funny that way.

Michigan

Q - you've stated on more than one occasion your (strong) preference for not making the employer the plan administrator. Care to share your reasons?

Don't you love irony?!

Thanks, Effen. For some reason, my addled mind thought that PBGC would respond with something like "Thanks for the notice, we're taking no action at this time" or "We need additional information to determine what action, if any, we will take" or "We're coming in to terminate the plan."

Don't know why, but I had it in my mind that the PBGC was required to respond within 60 days to a notice of reportable event. Of course, I now cannot find any reference to such a requirement and, in fact, have not run across anything that places any duty on the PBGC to respond. Any practical experience with when and how the PBGC responds to reportable event notices? Is anyone aware of any requirement that the PBGC respond within a specific time frame to such a notice? Thanks!

How do you measure contributions/benefit if the spouse has no compensation?

I agree that the employee should be reimbursed. I don't see the practical difference between paying the expense with the crisp $20 bills packed in a birthday card or using a gift certificate. The employee paid a qualifying medical expense and is entitled to reimbursement.

Kirk, The goal would be to provide benefits with the same tax effects as provided to employees, eg cost of coverage and benefits excludable from income.

I'd like to bump and twist this one in hopes of getting some traffic. Let's change slightly. Can an employer's self-insured health plan cover non-employee members of its board of directors?

This is one of those "I know there's something out there, but can't find it" issues. Can a self-insured medical plan cover a retired member of the board of directors (assume he/she was never an employee)? Seems it should be OK, assuming the plan meets the non-discrimination rules, but I just can't find anything addressing this issue, so far. Thanks.

Both of you raise excellent points. Thank you.

Can someone help me determine if I am reading the definition of "de-identified information" correctly? Reg. 164.514(b)(2)(i)© seems to provide that it is OK to not remove an individual's year of birth in creating de-identified information. In other words, it looks like a de-identified record could not include an exact birthdate, e.g. 1/1/1973, but could show the year of birth, e.g. 1973. Any thoughts?

Short digression, please. What is IANAL?

I must be missing something. I thought that withdrawal liability was calculated as a lump sum amount. If the employer chose (as most do) to pay over time, rather than in a lump sum, an interest factor was added in order to make the stream of payments actuarially equivalent to the lump sum amount. This question seems to be putting the cart before the horse (probably a bad analogy, but what the heck).