RatherBeGolfing

I have used the signature feature in Acrobat for years, never had an issue. DocuSign type digital signatures are common for contracts, but are only accepted on a short list of IRS forms. Ft Williams uses a DocuSign type e-signature in their Distribution Tracking Software. Some RK forms specifically say Acrobat digital signature not accepted. You can use the digital image of your signature to sign it, but not the DocuSign type signature. JH will accept a form signed with DocuSign, but only after confirming with the person who signed it

I thought the IRS only had a very short list of forms that were approved for electronic signature... To be clear, Im talking about a digital signature like DocuSign, not an image of your actual signature that is digitally added to the form.

Enjoy retirement!

It applies only to the 1 year vs 3 years income inclusion.

The Source is a NTSA publication that specifically deals with the 403b/457/government plans. It doesn't have the cross appeal that the EOB does, but its possible that it has some useful information.

I find this incredibly difficult to believe. Agreed. This usually means "we don't track hours, and we have no intention of doing so for the plan"

There is no reason why you would get a penalty for an that error, you are just correcting a reporting error that has no impact on the benefits or rights of a plan participant.

I agree with @Kevin C, it is a numbers game for those close(ish) to audit territory. The regulatory agencies are aware of this and Im cautiously optimistic that we will have a solution before we are actually required to bring the LTPT EEs into the plans. Other consideration: Possible impact on fees Extra administrative work (especially if plan responsibilities are simply added to an employees existing workload - includes everything from more paperwork for new employees, enrollment, notices, distributions, possible missing participants, etc.

If none of the assets are participant directed? Yes.

Bill channeling his inner @Mike Preston 😀

I'm going to split hairs a bit and ask for a clarification. Do you mean a fiduciary responsibility (legal, must do) or a moral responsibility (should do)?

Did the sponsor sign and file electronically or did you sign and file on their behalf with a copy of the signed 5500 attached? When you amend, the original filing is replaced with the amended filing. If you have an attachment with your filing, there will usually be a delay as the DOL will verify that there is no sensitive information posted for public viewing. You might have a short time when no filing is visible while the original is removed and the amended has not been checked.

For plan document purposes or compliance module?

@S Derrin Watson Thanks Derrin! Really appreciate the input from you and Ilene!

Yes, since the 2% shareholder treated as partner is only for filing purposes.

Thanks Ilene!

If you submitted them around the same time, chances are they will get a notice. I think they stopped processing most of the mail in March 2020

Im pretty sure this came up during ASPPA All Access as well, with the answer till being VCP. I think it was either Heather or Kelsey.

100% do not rely on IRS figuring it out on their own, but it does happen. Its still on the taxpayer if something is missed though.

This one you do need to contact the IRS on. This happens from time to time and you can usually solve it quickly by providing proof that you mailed it timely. If you have a lot of them, you can ask the IRS to send a list of all clients in the batch on electronic media instead of responding to each one individually.

I agree, no need to call IRS. They are processing late (or later than the normal late) because the IRS had offices closed down and a lot of mail went to storage unopened.

Yea that makes sense, thanks!

I do the withholding and deposits for most of my clients. Those funds go to an omnibus account for my firm, and at no time do they go through the employer. The taxes are paid to EFTPS by my firm as a reporting agent on behalf of the plan. For IRS purposes, the plan made the deposit, not my firm. In cases where you outsource the payment and reporting to a third party, you basically transferring the benefit to the third party for payment. It comes from them, not from you (the plan). If Ameriprise paid benefits and deposited withheld taxes using its own name and EIN, they would do the 1099-R and 945. If they did the deposit as a reporting agent (on behalf of the plan), the plan is still the payor. There should be no situation where YOU issue a 1099 or 945 using in Ameriprise's name and EIN. The client needs to find out what services they have engaged Ameriprise to perform, period.

Did OP confuse age 72 RMDs in SECURE with the RMD relief in CARES that was optional?

This. The payor is the PLAN, not the brokerage firm.