dmdavala

I had a similar situation and billed the client. The client loved the solution.

All of those were considered and not an issue. The amount does not trigger an accounting settlement either.

I have a client who is considering purchasing annuities for some of the retiree group. Their attorney says a plan amendment is required. I have never heard of a plan amendment being required in this circumstance. Has anyone heard of an amendment being required in this situation

Deductibility is not the issue. If the April and July payments are classified as 2016 contributions, has the sponsor missed the April and July quarterly requirements? The Carryover balance that was created by the extra contributions was not created until September when the final contribution for 2016 was deposited. Since the Carryover was not created until September, are the April and July quarterlies late?

A calendar year plan has $0 Credit Balance and $0 Prefunding Balance. Quarterly contributions are required. The sponsor has standing elections to increase the Prefunding Balance and use it to meet quarterlies and minimum requirements. The sponsor has been timely contributing the quarterly requirements when due. It is now September 18, 2017. The actuary has confirmed that all of the required contributions for the 2016 plan year have been timely made. The April and July quarterlies for the 2017 plan year have also been timely made. The actuary decides that if the April and July 2017 quarterlies are deemed 2016 contributions, then a Prefunding Balance will be automatically created. This Prefunding Balance can then be used to meet the April and July quarterlies. (Assume the excess contributions create sufficient Prefunding Balance to do so.) My question is, is this allowed? When was the Prefunding Balance created? If used to meet the April or July quarterly, didn't it have to exist when the quarterly is due?

I have a plan that has a very rich death benefit. If an active participant dies then the spouse gets a 100% J&S payable immediately. There is no reduction for early retirement. The normal form for the plan is 10cc. The benefit is converted to 100% J&S using the plans factors. A participant aged 45 died. The spouse is 41. My question is how to calculate the 415 limit on the benefit. I assume that I would reduce the dollar and pay limits to age 45 by using plan and applicable assumptions and take the lesser of these. What if the spouse decides not to immediately commence benefits? The plan provides for actuarial increase from the date the benefit could have commenced. (Month following death) The benefit will increase each month. Does the 415 limit increase each month also? Do I use the participant's age or the surviving spouse's when calculating the limit?