RatherBeGolfing

We rarely charge unless we need to go into the paper archives for stuff, but this sounds like the type of PITA client I would charge unless I have a good working relationship with the new TPA. How much is the old TPA asking for?

It depends on the situation, but they are probably within their rights to require "reasonable compensation" if they have to reproduce a product they already delivered.

Agreed. The only thing that changed were the limits. Those changes are effective for taxable years beginning after December 31, 2019. Assuming its a calendar year plan and otherwise eligible, limit is $500 in 2019 and $5,000 in 2020. See § 45E

I don't think so, the client fired them mid 2019, so I would assume they DID get the 2019 plan year notice. It is the notice for the current year that wasn't provided since the TPA believed they were fired during the time the notice (and instructions) would have been sent to the client. Notice requirement or not, I agree with you that the IRS probably wouldn't make a big deal out of it though.

Yes. § 45E(c)

Just did! I took me a while to realize that you have to fill out both the post and poll tabs rather just one, but once I realized that it was easy to do and looks great. Thanks Dave

(stealing Belgaraths topic to try out the poll feature )

Thanks Dave!

The form wasn't on my radar until now either. 100% agree with @Bird, if we don't do it no one else will.

@Dave Baker Just throwing this out there, a poll/survey feature would be really cool for threads like these

After 12/31/2019. If you hit 70.5 on 1/1/20 you are in the 72 group.

I think most documents reference the code section rather than a specified age, but it would probably depend on the document.

I think Form 945 is pretty common though. Unless you outsource it of course

Thanks Larry!

Also the ability to repay the distribution. I have heard that it would be added as a new hardship, but I haven't seen anything concrete on that.

Participants. But for plan purposes, participant means anyone eligible to participate, even if they are not making contributions now.

Yes. (d) EFFECTIVE DATE.—The amendments made by this section shall apply to distributions required to be made after December 31, 2019, with respect to individuals who attain age 70-1/2 after such date.

BILLS-116hr1865enr.pdf Page 623

Turned 70.5 on or before 12/31/2019, 70.5 applies Otherwise, 72 applies

Correct.

CCH Prosystem fx Engagement

I agree with the above. Catch-up is not included for 415 limit, so total contributions (including catch-up) CAN exceed 100% of compensation.

I haven't seen this addressed specifically, but it is a good question. Are they eligible for the current credit limited to $500? If so, they should be eligible for the increased credit as well 45E references 408(p)(2)(C)(i) to define the eligible Employer 45E references 4972(d) to define eligible employer plan

I don't see why not. It should also be pointed out that for Section 112 ,periods beginning before 1/1/2021 are not taken into account, so 2024 will be the first plan year to include one of these participants. I'm optimistic that we can get regulatory guidance in the meantime to deal with audit issue this creates.

From a cutback perspective, there is no protected right to continued participation, only to benefits already accrued. So if you have eligibility that less than the statutory maximum, an amendment could make a current participant ineligible for continued participation until new eligibility is met. Some documents default to grandfathering current participants, others it would depend on the amendment. You would still have to make sure that the amendment itself isn't discriminatory. EOB (Ch 2, Section VI, Part E)