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Mike Preston

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Everything posted by Mike Preston

  1. Mike Preston
    I have seen some pretty aggressive stuff in the wild. Never seen the IRS even raise the issue.
  2. Mike Preston
    James, just how much time would you take? Isn't this just 1 1099? How much do you think you can save?
  3. Mike Preston
    Luke, have you ever seen that applied? IRL? I haven't.
  4. Mike Preston
    Show me where it is not allowed. Or, at the least, something that indicates it may not be allowed. Sheesh, time to find some real work, huh?
  5. Mike Preston
    You can't find clear guidance on it because you can't do it. I'd be very curious to learn the basis behind "We think".
  6. Mike Preston
    I think you should start over and give numbers and dates. It doesn't sound like you have all of the facts.
  7. Mike Preston
    You will need to gather up as much of the documentation you can get your hands on (distribution election packets, Summary Plan Description, Plan Document, signed election forms, a written history of every check you have received from the plan) and then either hire an expert or have a volunteer from the link I sent assigned. Good luck.
  8. Mike Preston
    A friendly reminder that the IRS considers the combination of "everybody in their own group" and "1 or more participants, whether HCE or not, receiving $0 for the year" invokes the prohibition on using the Average Benefits Test to satisfy coverage. While not typically a problem, if the plan also carves out for eligibility it could become an issue. FWIW
  9. Mike Preston
    They do.
  10. Mike Preston
    Go here: https://www.actuary.org/content/pension-assistance-list-pal Good luck.
  11. Mike Preston
    My quick read of the article leads me to the conclusion that the author is narrowly discussing aggregation of 403(b) with 403(b). I don't think the article is saying anything with respect to aggregation of 403(b) with 401(a). I could be reading it wrong.
  12. Mike Preston
    The former.
  13. Mike Preston
    Nope.
  14. Mike Preston
    How do you do that now?
  15. Mike Preston
    My fingers say 2015 or later because correcting under SCP by end of 2017 is a hard slog in March of 2018. And I would say there is a possibility that the correction is with respect to an insignificant error and, if so, SCP might still be available. Otherwise, it is VCP or audit lottery.
  16. Mike Preston
    No, assuming the plan is drafted accordingly.
  17. Mike Preston
    It is my understanding that they do in California.
  18. Mike Preston
    Amend through EFAST. Hard to imagine anything could possibly be more efficient.
  19. Mike Preston
    Effectively untrue. Insurance companies have been known to develop boutique policies. Do a google search on "springing cash value".
  20. Mike Preston
    Just have to agree to disagree, then. The mere fact that the non-SH plan constitutes an "exclusive" group means that it is more than just merely possible that coverage is being satisfied with reference not to 70% but to the safe-harbor percentage (50% or lower). If so, then it is also possible that the ABT is failed unless all plans are considered. If so, then the non-SH plan satisfies coverage only by including the SH plan in the ABT. That is enough to make the non-SH plan part of the required aggregation group.
  21. Mike Preston
    What is your point? Are you trying to argue that a plan that satisfies coverage gets a free pass as to non-discrimination?
  22. Mike Preston
    You also have to aggregate plans that are used to enable a TH plan to satisfy 401(a)(4). This can mean all plans if a plan needs the ABT.
  23. Mike Preston
    We appear to be in an infinite loop.
  24. Mike Preston
    Substitute "increase the likelihood of a reversion".
  25. Mike Preston
    Perhaps there is a limit to the extent that future works? Maybe a monthly rate published around the first of the month allowing that rate to work for anything projected to the end of the month?
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