TPA2015

We were recently contacted by a doctor, who received a CP214 Letter in February this year. His mother, who recently passed, took care of filing the 5500 EZ for him. Neither the doctor or the accountant have been able to find copies of the prior filings. Would submitting the IRS Form 4506 be the only way to obtain a copy or is there another option?

An employer allowed an employee to begin deferring in 2017, but they are not eligible until 2018. The employer does not want to use the EPCRS amendment correction method so that the participant would be eligible for 2017, since they would be required to provide a top heavy minimum allocation. If the early deferrals plus gain/loss are returned to the participant, what 1099 code should be used? It seems like it should be a 2017 tax event.

I agree that if the plan used the per payroll definition, you would only look at the Company A compensation, but for this plan the compensation definition for the match is for the full plan year, which will require a true up. The plan is on the Relius volume submitter document, and it does provide that for discretionary PS the allocation will be determined employer by employer, but I am not seeing the same language for the safe harbor match. thank you

Company A and Company B form a controlled group. Company A sponsors a safe harbor match 401(k) Plan, which Company B has adopted as a participating employer. There is one employee, who receives compensation from both entities, but all of the deferrals have been made through Company A. For purposes of calculating the safe harbor match, I believe I should aggregate the compensation from both companies. For deduction purposes, should the safe harbor match contribution for this person be divided prorata based on compensation, or should the entire deduction be taken by Company A, since the deferrals were made by the employee from his Company A compensation.

A participant, who is 72 years old, works for a company (Company A), which is owned by an unrelated third party, and also works for a company (Company B) that she owns with her husband. In 2017, she took an in-service distribution from Company A's 401(k) and rolled it to the Company B's 401(k), which was established in 2017. Company B has also sponsored a DB plan for several years and she has been taking RMDs from the DB since she was 70-1/2. Since she did not have an account balance in Company B's 401(k) at 12/31/16, would 12/31/18 be her first required minimum distribution date from the 401(k)? §1.401(a)(9)-7 Rollovers and transfers. Q-1. If an amount is distributed by one plan (distributing plan) and is rolled over to another plan, is the required minimum distribution under the distributing plan affected by the rollover? A-1. No, if an amount is distributed by one plan and is rolled over to another plan, the amount distributed is still treated as a distribution by the distributing plan for purposes of section 401(a)(9), notwithstanding the rollover. See A-1 of §1.402(c)-2 for the definition of a rollover and A-7 of §1.402(c)-2 for rules for determining the portion of any distribution that is not eligible for rollover because it is a required minimum distribution. Q-2. If an amount is distributed by one plan (distributing plan) and is rolled over to another plan (receiving plan), how are the benefit and the required minimum distribution under the receiving plan affected? A-2. If an amount is distributed by one plan (distributing plan) and is rolled over to another plan (receiving plan), the benefit of the employee under the receiving plan is increased by the amount rolled over for purposes of determining the required minimum distribution for the calendar year immediately following the calendar year in which the amount rolled over is distributed. If the amount rolled over is received after the last valuation date in the calendar year under the receiving plan, the benefit of the employee as of such valuation date, adjusted in accordance with A-3 of §1.401(a)(9)-5, will be increased by the rollover amount valued as of the date of receipt. In addition, if the amount rolled over is received in a different calendar year from the calendar year in which it is distributed, the amount rolled over is deemed to have been received by the receiving plan in the calendar year in which it was distributed.

A terminated participant was provided a distribution check for $150 in December 2016. In 2017, the investment company determined that the check was never cashed and has reversed the transaction and is including the funds in the plan's assets. A new check was written in June to the participant and he is cashing the check. For 5500 reporting, at 12/31/16 should the stale check be included in the ending asset balance? Also, should the 2016 1099R for the participant be amended to reflect $0 distribution and a new 1099R prepared for 2017 showing the payment?

An advisor forwarded a copy of a CP220 letter that his client received, which reflects a substantial fine. The client is currently with another TPA firm and filed their 2014 5500 in 2016 after receiving an initial notice, but they did not file under DFVC. They filed the 5500s for other years in a timely manner. At this point, is the main option available to the employer, a letter regarding the difficult circumstances that resulted in the late filing in the hopes of reducing the penalty?

Has anyone restated an existing governmental plan, which has been maintained on a Volume Submitter Money Purchase Document, onto the Sungard Governmental Volume Submitter 401(a) Plan Document? Did you provide a 204(h) notice?