Jim Chad

I think you are right. FWIW I think you should do true up for everyone.

Each person in their own group would allow this. But it would not be safe harbor and would require testing.

I have filed a 5500 EZ for a Sole proprietor in 2012 and 2013 with the owner's social security number for sponsor's EIN. Yesterday the client received a letter from the IRS saying that the 2013 had the wrong EIN. They stated that the form had the owner's social security number and gave a number that they said was the correct one. The owner has no idea what this number is or where it came from. Does anyone have any suggestions?

Wouldn't it be better to do a Roth inplan conversion immediately?

Email me at Jchad@lettinga.com

I just heard from a business owner that she was told that RMD's did not apply to SEP IRA's. Is this true?

Belgarath. I will vote for you for dictator.

I would try to see if all testing will pass if you do the merger on 9-30? If yes, than that would be my choice. By the way, are you anywhere near 100 Participants?

I can't understand what you are saying. Would you care to try wording it differently. Maybe I would be able to understand. Company A: Does John own 60 % or does the trust own 90%? I don't understand how it could be both.

Can he correct under EPCRS by funding before 12-31-14?

To clarify what kind of plan, it is a Profit Sharing 401(k) Plan and he is about to make a big discretionary non-elective contribution. And thank you for all of the comments. A lot of good food for thought.

A client is worried about the economy and would like to put a few hundred thousand dollars of his Profit sharing into precious metals? Can anyone tell me if this can be done legally? and who does it well?

I will start this discussion with the idea of using the 3% assumption used for first year plans. Anyone else have any ideas?

I disclose a "fee to close dormant accounts". And I take whatever the account is, when it is below that threshold.

Thanks, Tom. I'm looking for a place in the appendix to put in that nobody can be rehired....EVER. LOL

In most plans, do you have rule of Parity for both Eligibility and vesting? In the appendix of the Corbel document, I can exclude either or both.

FWIW I think you are right. Anyone else?

I'm inclined to always recommend yes for "allowing distributions for deemed severance of employment". Does anyone see any drawbacks to this?

Can I have retirement age of 62 in my document and do all of my testing using age 65?

Correct. I am talking about 401(k) Plans which are the only document work I do. (Some Profit sharing)

Thanks folks. This was really bothering me.

What does "deemed severance of employment mean"? and do we want to allow distributions for it?

What advantages do people see to having 65 for retirement age? if you have 62 and 5 years, then vesting is almost the same. If retirement age is 62, then you could force out termed Participants at age 62. What are you all doing?

I was thinking if he is under $5,000 and moved to an auto IRA before the plan termination he would not be 100% vested. otherwise he would be fully vested.

If he has less than $5,000, you can force him out now. And FWIW I think he would not be 100% vested. What do others think?