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WCC

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WCC last won the day on August 29

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  1. The auditors we work with look at every period on a spreadsheet to determine the number of days it took for each withholding to be deposited. If they determine the company can reasonably make the deposit within say 3 days, then that is the standard for that company. No, nor should they.
  2. Here is a recent chat that may help.
  3. Just trying to learn here for my own knowledge, but is this above statement correct? IRS notice Q&A-8 of Notice 2013-74 talks about the 5-year clock, but does this mean it starts over with every conversion? I was under the impression there was only one 5 year clock per participant in the plan, but maybe I am wrong. I could not find anything directly on point in the EOB. If someone were converting after-tax to Roth immediately every period, or converting PS dollars every year to Roth, they would have a new 5-year clock with every conversion? Curious of your thoughts.
  4. here is the regulation cite if helpful. Treas. Reg. §1.401(m)-3(j)(6)
  5. No, they do not. HCEs don't receive any special treatment when it comes to deposit timing. Are you asking about self employed individuals? If so, then this thread may help.
  6. Unless the plan documents says otherwise, this paragraph from the preamble to the 415 regs is what I have relied on when this question comes up. You are not required to count compensation on a FIFO type accounting basis. https://www.federalregister.gov/d/E7-5750/p-111 "As noted above, the final regulations provide that a plan cannot take into account compensation in excess of the section 401(a)(17) limit. In addition, the final regulations provide that elective deferrals can only be made from compensation as defined in section 415(c)(3). However, in applying these two rules, a plan is not required to determine a participant's compensation on the basis of the earliest payments of compensation during a year."
  7. Can't you just force them out to an IRA due to plan termination under Treas. Reg. §1.411(e) regardless of the existing threshold?
  8. Asking about employer contributions such as match, profit sharing, etc.
  9. Is anyone aware of a tax change (effective 2024) requiring employers to pay FMLA and unemployment taxes on employer contributions for the year the contribution is made for residents of Massachusetts only? Google searching did not result in any answers to confirm if this inquiry is indeed accurate. Thank you
  10. I will attempt to answer this. The participant loan is a plan asset and earns interest which just happens to be paid by the participant. The interest is a plan asset since it is earned on a plan asset. In this case, the loan is part of the participant directed account so the participant is choosing how the funds are "invested" and the participant is earning interest on their loan asset. When payments are made to the plan, the cash buys shares of the TDF. So in your example the $1800 of interest buys shares of the TDF in the participants account. it is similar to any other investment in the plan. If you own a mutual fund that pays dividends, those dividends are reinvested in your account and they buy more shares of the investment.
  11. Traditional 401k plan has an ACA feature with auto escalation (not EACA nor QACA). Plan is a calendar year plan but auto escalation occurs on July 1 to coincide with pay raises. Plan provides annual ACA and escalation notice between 30 - 90 days before the beginning of the plan year. Question - since the escalation takes effective later than 90 days after the annual notice is given, is a second notice required to be given later in the year? I have searched the EOB and these boards, but can only find notice references when the escalation occurs on the first day of the plan year. I am thinking a second notice should be given, but am getting push back to prove it. Thanks
  12. I am having trouble finding guidance on this and hoping someone can point me in the right direction. Participant took a $100,000 CARES Act distribution in 2020. Proceeds came from: Roth deferral = $50,000 Pretax deferral = $25,000 Match = $25,000 Participant makes a repayment of $100,000 in 2023. In to what sources are the funds deposited at the time of repayment? Roth = $50,000, Pretax = $25,000, Match = $25,000? Or Roth Rollover $50,000, Pretax Rollover $50,000? Some other method? Thank you
  13. If the error had not occurred, would she have received match? If so, then she should receive 100% of the match that she would have received had the error not occurred. (Rev Proc 2021-30 Appendix A Section .05)
  14. 5 year clock starts the year the first Roth contribution and/or conversion is made in the 401k. Keep in mind if he satisfies the 5 year rule in the 401k, then rolls to a brand new/newly opened Roth IRA, the 5 year clock starts over.
  15. Hello, As we know, SECURE 1.0 and SECURE 2.0 increased the RMD age. Let's say a DB plan kept their distribution age at 70.5 and continues to pay mandatory distributions at 70.5. Let's assume a participant turned age 70.5 in 2023 and the DB plan will pay the first "RMD" by April 1, 2024. Can a participant roll that payment to an IRA and avoid taxation since the plan is forcing the distribution sooner than they otherwise are required to? Does by virtue of the plan keeping the RMD age at 70.5 make this an RMD? Or does the participant have any individual choice to roll it since it is paid before 73? Thank you for your thoughts.
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