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Got a plan that has always been a closed MEP due to common ownership. For some reason, it was thought by a previous provider that this MEP was open and needed the two employers to file separate 5500s going back to 2018. My question is how do you amend a 5500 that should never have existed? The only option I can really think of is to just amend last year's returns and show it as a transfer of assets to the "main" plan and as a final 5500.

Have a client that failed to give a 30 day fund change notice to participants. From what I can tell, there is not an actual penalty prescribed by the DOL other than a plan sponsor could be held liable for a fiduciary breach. Based on this I was going to advise them to just give out the updated notice ASAP. Anything I am missing?

I think I would make a special deferral election form and just have the participant elect to not have deferrals come out of that special income.

Anyone have the new table available in Excel?

Got a client that signed a plan document but never did anything with it and terminated it in the same year it was effective. Do you think a 5500 should be filed for this one and only plan year?

Bill, just texted you.

Anyone have a good recommendation out there for contribution projections for prospects? The only one I can think of is Relius Proposal but it has been discontinued. Any other good ones out there?

I generally see two schools of thought on this topic: 1. Process the conversion as a distribution and a rollover. 2. Process as a transfer and it is just a wash so no 5500 reporting. Does anyone know of any formal or informal guidance on either of these? I haven't been able to find anything.

Just a 401k plan. It would be a profit sharing receivable. Normally I would say it would be based on cash basis balance, but the more I look at the instructions, I start to interpet it in the opposite manner.

I am not referring to that. I am referring only to line 6g -- participants with an account balance.

In regards to line 6g, if a plan that is filing on a cash basis, should it still include participants that have a receivable at the end of the year? These participants would have a zero balance without the receivable.

Anyone ever created a spreadsheet to mimic the DOL calculator that one could just copy/paste the information into the spreadsheet? Sure would be easier than doing them one by one on the DOL page.

That is what I thought but that evil foe named "Doubt" crept in my head. :-)

Had a plan amended to now include a formerly excludable class of employees during the year. Is the compensation for the top heavy minimum for the full year or is it just for the part of the year that they were actually includable?

Thanks, that is what I thought but couldn't find the documentation.

For a sponsor that sends in deferral deposits by check, does the IRS/DOL consider them segregated/deposited as of the date the check was mailed or as of the date the check was actually deposited?

Seems like I remember something about distribution fees are not allowed to be charged to participants for ADP refunds and similar transactions. However, I can't find this anywhere. Can one of you point me in the right direction?

I believe so. Can you give me more information? I am definitely not familiar with this.

Have some owners/officers that bought company stock in their IRAs years ago and now they want to sell it. Problem is the company is the only willing buyer which would be a PT. Anyone aware of any court cases or anything that might give these guys a way out? I am thinking that they would not be granted an PTE for this.

I am aware of this but does a welfare benefit plan sponsored by a governmental entity automatically make it a governmental plan?

Does a governmental entity (with more than 100 participants) that sponsors a welfare benefit plan have to file a 5500 for it?

Belgarath, I agree. Assuming it does pass 414 test, the safe harbor match is fine.

Your determination date is the last day of the prior plan year. In your example, they would be considered key employees for 2013.

Shenanigans.

I would also agree. $44k sounds ridiculously high for standard services.