RatherBeGolfing

Agree with @Bird. Repaying a CRD to an IRA is not a contribution. You will see some people refer to it as a rollover since a 401(k) plan that receives a repayment would treat it as a rollover asset. It is treated as a trustee to trustee transfer, so its not a contribution, and it does not count as a rollover for the one IRA rollover per 12 months rule.

Depends on the document. Does the plan treat loans as a segregated investment (Earnings to participant with loan) or as an investment of the trust (earnings to all)

Retirement plan contributions are eligible for PPP forgiveness, but this is 100% a question for his CPA. If CPA cant answer or is passing the buck, it is time for a new CPA.

If all participants would be considered 2% shareholders of the S-corp, by direct ownership or attribution under 318, you would treat all participants as partners for filing purposes. A plan that covers only partners would file an EZ.

I have the same confusion as Bill and Bird... Or are you just looking at it as a timing issue? Client made $10,000 contribution in February and got $100,000 in PPP funds in March, can you count the $10,000 as a PPP funds spent on the retirement contributions? Is that the question?

@C. B. Zeller beat me to it by a minute or so haha. They didn't really add attribution. All they did was expand the Form 5500-EZ eligibility by treating 2% S-corp shareholders as partners for filing purposes. The only reason we are talking about attribution here is because the definition of 2% shareholder includes attributed ownership.

Peter, I think it is more likely that most TPAs (and probably RKs) do not do this because they do not offer investment or financial planning services, and they emphatically stay on the other side of that line for good reason. If you are not a tax advisor, you should not provide tax advice. If you are not an investment advisor or financial planner, you should not provide investment advice. There are so many variables that going beyond "speak to your tax and investment advisors" is getting into territory where you should not provide such advice unless you are qualified (and licensed/insured) to do so.

Yep same process here and same speed reader clients In most cases there was time for review prior to final document going out for signature though.

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!