RatherBeGolfing

How large?

First payroll won't process until mid October - so its tight on time but doable Thank you both!

It's one of those days and this just came up A client that does not currently offer a retirement plan just (like last night) acquired a new division with employees who are under a CBA. The CBA states that the employees must have access to a 401(k) plan with a safe harbor match and an additional fixed match. He currently has about 40 employees, and the new division will add 7-8 employees covered under the CBA. Since it is last minute, he wants to put the plan in place today, but exclude all employees not covered by the CBA. The 7-8 CBA employees are all NHCEs, all owners and HCEs are part of the excluded group. I know I can do it from a document perspective, and since no HCEs will benefit I'm thinking that covering a small number of employees will still work, but something is telling me Im forgetting something.... Anyone see a an issue with only the CBA employees having access to the plan even though they are all NHCEs? Thanks

Reporting to SSA sounds like they simply reported you as a code A on Form 8955-SSA because you had not received a distribution of all assets by the and of the year following the year of termination. This just means that the plan still holds assets for your benefit. Unless you receive a distribution of those assets AND the employer reports that distribution to SSA, the SSA will send you a letter at age 65 saying you may have retirement assets in the following plan(s).

IRS rep? If the returns are truly late and you still have an opportunity to use the late EZ correction program, do so ASAP. Even after they knock it down to the pre-2020 penalty amount, you want to take advantage of paying $1000 instead of $30,000

Why would someone from Relius be moderating the message boards on a third party site?

You can get a bond with retroactive coverage. I know Colonial Surety does them, not sure about other providers

Last year, they sent out notices for pre 2020 plan years using the post 2019 penalty. This was fixed at the time, but may back again. It is not that uncommon to have wrong dates on these notices, so could be either really. Agree with above, call the IRS (with a POA so you don't spend 3 hours on hold just to have them say I cant talk to without a POA)

Yep, another vote for run. While you are doing so, make sure to follow your engagement agreement (notify in writing, bla bla bla) I had a similar one recently that was 2 years behind on safe harbor match contributions. I told him I would resign and not prepare any government forms, nor would any else if her persisted with the "can't pay" BS. It was really silly too, because most of the safe harbor contribution would go to him and his wife. It took me, the CPA, and his FA to convince him that the trouble he could or would be facing (including fines and possible criminal charges) if he didn't fund the contributions (or made other arraignments through VCP) just wasn't worth it. He finally "found" the money and made things right (contribution plus actual rate of return).

How do we get around the "plan just cut her a check" part? I believe MT and Penchecks both have an uncashed check solution (which is basically an after tax IRA), but in this case you weren't supposed to cut the check in the first place, so I'm not even sure that it is technically an uncashed check. I think the correct way to fix it is to restore the account until you have a proper distribution.

Scheduled to be published 9/15. Includes audit waiver eligibility based on account balances rather than eligible participants. https://www.federalregister.gov/public-inspection/2021-19714/annual-information-returnreports

This is for DC plans

I already have... I have a couple of employers dragging their feet (maybe next year...) but they really need plans for several reasons. I have told them that between SECURE 2.0 and the bill being marked up now, the window is closing. Its clear that this is happening, its just a matter of time.

So in other words, grandfathered plans will be a sought after commodity for exhausted TPAs!

Its just a small part of a much bigger legislative text, but yea I would like to have this one taken out as well. There are other parts that are much more "exciting"

Small plans still may be required to issue Forms 1096, 1099-R, and 945, which will use the Trust EIN. I'll also note that the proposed changes to Form 5500 includes a line for the Trust EIN, even though the 5500 itself uses the sponsor EIN.

B.1.617.2?

Are you looking for an audit of your firm, or for plan sponsors?

Distribution out, Rollover in

I have not seen one so far. We use FTW

CARES wasn't extended, the last day for a CRD was December 30, 2020. The qualified disaster distributions in CAA21 did not include any area where a major disaster had been declared only by reason of Covid-19. You needed something like a hurricane, wildfire, tornado, etc. If you were trying to get a distribution just because of Covid, you were out of luck after December 30, 2020.

Fair enough

HA, Me too! I have never understood piggybacking a thread from a few years ago (or 20!) with "same, but different facts...." instead of just starting a new post.

Unless that $78,000 is from 2020 and/or 2021, the IRS would strongly disagree with the "no misses" part...

In your example, the coverage amount is 200k. You should report 200k. In OPs example, the coverage amount is more than the required amount. You still report the coverage amount, not the required amount. For example, if the required bond is X and the bond coverage is X+100k, you report X+100k.