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I am trying again. Deferral.zip

A plan allows participants to refinance (replace) loans in order to take out a greater amount that is needed. I know that the sum of the replaced loan and the new loan cannot be greater than 50% of the vested balance as of the origination date of the new loan. My question is should the vested balance used to calculate the 50% include the value of the old loan?

I added the features but to my own report. I was really hoping that I could make one report that would show all of my plans on one report with the number of those deferring and non-deferring but I can't think of a way to do that. I tried adding the report but I keep getting an error that says "You cannot upload this type of file".

Can anyone think of a way to create a report that would show participants that are deferring vs. participants that are not deferring?

They have worked most of the bugs out now. The new features are great especially if you are using the daily platform.

JohnCheek, yes I was referring to the welfare plan requirement with more than 100 participants. That is what I figured but needed some reassurance since I do not deal with cafeteria plans often. GBurns, you are correct that they do have options to do different services with this PEO. However, they all do use the cafeteria plan. I am asking the filing requirement for the multiple employer plan.

I have a multiplemployer plan sponsored by a PEO. The PEO handles most of the employee benefits for all participating companies. Some of the sponsoring companies have the cafeteria deductions come straight to them and other have the cafeteria deductions go straight to the insurance companies. Is it okay to file one form 5500 for this plan or does this issue cause multiple 5500s to be filed?

IRC 413©1 for eligibility and 413©3 for vesting. I think I may be misinterpreting these regs now that I re-read them. It should be that service for eligibility and vesting has to count with any of the participating employers that an EE works for. Would that be the correct interpretation?

The regs state that a multiple employer plan has to have the same eligibility and vesting requirements for each participating employer. Does anyone know of a design or loophole or other reg that would allow participating employers to have different eligibility and/or vesting requirements?

It really is a very gray area. I would say the conservative approach is to apply forfeitures to all plans. The more moderate approach (and the approach I would use until further guidance is issued) is to allocate forfeitures only to the related plan.

I have a multiplemployer plan sponsored by a PEO. The PEO handles most of the employee benefits for all participating companies. Some of the sponsoring companies have the cafeteria deductions come straight to them and other have the cafeteria deductions go straight to the insurance companies. Is it okay to file one form 5500 for this plan or does this issue cause multiple 5500s to be filed?

It is a new plan. I figured the first contribution to the plan would be a debit to the "retirement plan assets" and a credit to "retirement plan liability".

Is there any requirement that you break out unrealized and realized gains/losses on assets that are invested in mutual funds? I am curious as to how other practitioners handle this on the SAR. I have always broken the amounts out but I have recently started to think that since I don't have to break it out on the sch. H or I, why should I have to break it out on the SAR?

That is correct.

The merger resolution automatically transferred your assets into the profit sharing plan. You should show a transfer out on your 5500 for the MPP and a transfer in on the 5500 for the PSP.

I recently performed the same thing. I double checked with counsel on the correct way to do this and they instructed me that it should be done the way the original contribution was allocated under the document. In my case it was a discretionary match that I increased to everyone that deferred and was eligible for the match. This included the otherwise excludables.

No it does not have to be 100% vested. Your match formula is not a safe harbor match. You must have a minimum of 100% of the first 3% and 50% on the next 2%. The addition of the the profit sharing contribution will make the plan subject to top heavy rules.

The assets are going to be held in the general assets of the employer. You are incorrect about the offset. You would record a debit to "retirement plan asset" and a credit to "retirement plan liability" as used by double entry accounting. The term offset might not be a good word to use here. I may be misinterpreting you. Are you saying that the employer would never record any journal entries until distributions are actually made?

I have never helped a client setup the accounting for a 457 plan and have been asked to do so. Since this is an unfunded arrangement the client has to keep the accounting on the company books. My initial thoughts are to show the 457 plan assets as an asset with an offset using "retirement plan liability"or something similar. As distributions are paid out they would be expensed. Am I missing anything here?

The assets at 12/31/01 became part of the profit sharing plan. It became no different than two separate brokerage accounts for profit sharing assets and 401(k) deferrals.

The assets became part of the profit sharing plan on the effective date of the merger. The last 5500 for the MPP should have been for 2001.

I have a plan that failed to do ADP refunds for the 2001 plan year by the statutory due date of 12/31/2002. They have corrected this by using the one-to-one correction method. Should the refunds and the QNEC be shown on the 2003 5500 or should they be reported on an amended 2001 5500?

I meant to say get a copy of his K-1.

Does he actually do work for the company? If he is just a passive income owner then he would not be an employee. My guess is he does. His compensation would be his earned income from the business. I would recommend that you get a copy of his 1065 at the end of the year.

A plan failed to get a required audit performed for the 2000 and 2001 plan years. Due to sales of certain divisions of the company, adequate records do not exist to audit the financial statements for the related periods. What are their options, if any?