Jim Chad

Has he been married more than a year?

FWIW I think they can count the QNECs in the ADP test.

Wouldn't those be non deductible contributions for all of the years the Employer was not an eligible enmployer? Would this mean each Participant should amend their tax returns?

My understanding is that it is in the document so it is locked in. Does anyone know if this can be amended after the end of the Plan year?

I am having trouble with the 36%. I can't follow where that came from. If we test for coverage on acombined plan basis and exclude all union from numerator and denominator, what percentage do you get?

Does document say to calculate match on a Plan year or pyroll basis? or other? Do you have an IRS aproval letter? is it legal to have a 2 year wait on match?

Has this correction been changed by Rev 2013-12?

Some people call it a "Dormant account closing fee"

FWIW, I think you have 3 NHCE's and 2 allocation rates.

Thanks, BG5150 You answered one of my questions. I would like to be sure I understand the other question. Will taxes ever be paid on the phantom interest?

Is some of the interest on deemed loan taxable when account is all paid out? I think interest is still accumulated on the loan after it is deemed. Am I right on this? If a loan plus interest was $20,000 when deemed, then Taxes were paid on $20,000. If the loan "grows" to $25,000 by the time the Participant retires and the account is paid out, will taxes have to be paid on the other $5,000?

If it is a calendar year plan, then I believe the answer is no. There is no way to legally do s 2012 catch up now.

Hopefully this is in hte document. What does it say about compensation?

In keeping with the ideas in the examples, I would think an examiner would tell them to amend the document to define "nonbenefiting employees". FWIW

How about instead of raises in the future, he could start with a SHNEC and then add PS in future years? This is more like my father's DB plan in the 60's and 70's.....forced savings.

I know this has been discussed before. But I am wondering if there is anything new. There is a mortgage and we are being told there is no unrelated business taxable income and no return needs to be filed. I thought that if there was any debt that a UBTI return had to be filed and often there were taxes due. What do you all think?

yes

That looks like a pretty good suggestion to me. I think it fits well with Rev Proc. 2008-50. Good luck.

Thank you, Tom. And thanks for the chuckle, also.

Does anyone know what the penalty is for a late 8955 SSA?

FWIW I have never seen or heard of such a requirement. Has anyone else?

I wonder if the fees quoted are based on the large rollover amount and they do not want to do the work for the low fee on small amounts. They may have had the experience of months going by before the assets came over. This sounds like good business practice, to me, from the accounting department point of view. It is also a sales prevention item in the real world.

I think I know the answer but I'm hoping. Does everyone distribute a $15 RMD?

Thank you to all three of you. I really appreciate it.

I am not able to find the phone forums on the IRS site since it has been "improved". Can anyone provide a link? Also, I heard a speaker from the IRS say that they had a description of what "disqualifying a Plan means" on the website. Has anyone seen that and could you provide a link? Thank you.