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Everything posted by RatherBeGolfing
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401k Loan Amount - What is the max for me?
RatherBeGolfing replied to sarathesmith2's topic in 401(k) Plans
Your max at the moment is $39,500 -
How many times have you done it? I have had clients do this without talking to us first and it has taken many calls to the IRS to fix it. You may be one of the lucky few that didn't have this cause an issue. They normally wont return the check, but most of the time it wont be correctly applied as a 945 to the plan.
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Is rollover money exempt from the 10% penalty?
RatherBeGolfing replied to ldr's topic in 401(k) Plans
Lou is correct. Can't use code 2 now since she is still employed. She needs to wait or take the 10% hit- 17 replies
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- rollover
- withdrawal
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Like @Bird, we have a master EFTPS account and we do it for our clients. It is just much easier. Otherwise the plan has enroll with a plan account and make deposits electronically. Unless you do a ton of distributions, you are going to have an account with a $0 balance that is probably going to just eat up monthly fees, unless you have a friendly bank that will give you a free account to carry a $0 balance.... I believe the amounts / schedules are less than $50k in lookback period (last year) - Monthly schedule $50k or more in lookback period - semiweekly schedule (Wed-Fri due Wed, Sat-Tue due Fri) $100k or more due the next day, and you are now semiweekly schedule for the rest of the year and next year. I think the $100k accumulates each deposit period, so if you are a monthly schedule and and withhold $50k in the first and third week of a month, your deposit is now due on the next day and you are semiweekly schedule for the rest of the year. But, if you withhold $50k in the first week of two consecutive months, you don't hit $100k for either period so you are still monthly for the year but semiweekly for the next year.
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The sample test shouldn't tell you what questions/topics will be on the exam. The purpose of the sample test is to give you an idea of how the test is structured, what kind of questions will be on the exam, and to give you an idea of how to answer the questions and how much time to spend on each question, etc. For what questions/topics will be on the actual test, study the syllabus. Generally, the tests will follow the learning objectives and exam weighting pretty closely. The sample tests should help you with how to read the questions and take the test. - read the question closely and look for qualifiers (always, never, not, etc) - don't just pick the "right" answer, eliminate the wrong answers. The qualifiers will almost always eliminate a few answers for you - If you get stuck on a question, mark it and move along. When you are done, go back to your marked unanswered or toss up questions - Some people like to read the answers before the question, but it doesn't work for everyone. Try it on the practice exams. By knowing your options for answers, you may be able to eliminate one or two options as you read the question.
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Happy to help!
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Renewal Period - ERPA
RatherBeGolfing replied to Gilmore's topic in ERPA (Enrolled Retirement Plan Agent)
Yes and yes -
At what point is it appropriate to start this question with "Robert has blurb..."? ?♂️ Joking aside, isn't the point of the section you are referring to that if you have a successor plan you no longer have a distributable event due to plan termination? If a successor plan exists, assets with distribution restrictions (elective deferrals and SH) are not distributable due to plan termination if a successor plan exists, while other contributions like profit sharing and non safe harbor match would be distributable even with a successor plan in place. So any participant who does not otherwise have a distributable event, would have to have their restricted contributions transferred to the successor plan or stay in terminated plan until a there is a distributable event. This is assuming you have the successor plan in place at termination. If you distribute all assets and then establish a new plan within the 12 month period following distribution, you have a big problem with the distributions you already did...
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Suspending nonelective Safe Harbor mid-year
RatherBeGolfing replied to perplexedbypensions's topic in 401(k) Plans
Yep, I believe Derrin Watson coined the "maybe not" term in an ASAP or Relius update after they came out. -
@Pam Shoup suggestion above is great. It needs to be done by hand rather than typed on a computer. Studies have shown that doing it by hand increases memory retention significantly. When I was in law school I took all my lecture notes by hand and I did my outlines by hand before I put them into a word document. I do the same thing whenever I study for a designation or read a new proposed rule or law change. For actual studying I do something like this Week 1 Read Ch1 (or part 1, section 1, whatever), then outline Ch1 on the second read Week 2 Read Ch2 , then outline Ch2 on the second read, study Ch1-2 outline Week 3 Read Ch3 , then outline Ch3 on the second read, study Ch1-3 outline Do this until you have outlined all of the required material. The outline should mainly focus on the learning objectives from the syllabus unless there are new things there that you also feel are important. Since different sections are weighted more or less on the exam, you can substitute Ch1 above for whatever section is going to be used more on the exam, that way you read that outline each week and should know it well before the exam. There is no point in doing a 5 page outline on plan loans and a 1 page outline on testing if you are going to get one loan question and 10 testing questions...
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Do you feel like you know the answers while taking the test? Or does it seem like the exam is nothing like the practice exam? Are there certain sections that are tripping you up? I know they have changed how they do the exams since I took them but they used to tell you if you need to improve on a certain section like distributions or testing or whatever. Overall, the syllabus is your best friend. it tells you what you are expected to know from each section/topic, and what percentage of the exam can be expected from that section.
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testing each xt deposit... including receivable?
RatherBeGolfing replied to AlbanyConsultant's topic in 401(k) Plans
No. Its not an issue. It does not favor the HCEs. The only reasonable way to look at this to see if HCEs are favored is looking a deposits YTD A simplified example. 1 HCE and 1 NHCE. NHCE gets funded over 10 payroll dates during the year, HCE gets funded once after the end of the year. Deposit HCE HCE YTD NHCE NHCE YTD 1 0.00% 0.00% 10.00% 10.00% 2 0.00% 0.00% 10.00% 20.00% 3 0.00% 0.00% 10.00% 30.00% 4 0.00% 0.00% 10.00% 40.00% 5 0.00% 0.00% 10.00% 50.00% 6 0.00% 0.00% 10.00% 60.00% 7 0.00% 0.00% 10.00% 70.00% 8 0.00% 0.00% 10.00% 80.00% 9 0.00% 0.00% 10.00% 90.00% 10 0.00% 0.00% 10.00% 100.00% 11 100.00% 100.00% 0.00% 100.00% -
Do the two quoted sections above really mean different things? They both say that the plan may distribute immediately if the QDRO provides for it. If it was a requirement, if there was no choice at all, I would expect shall or will rather than may. I agree that it would be problematic for the fiduciary to have discretion on a case by case basis, basically deciding that AP1 gets a distribution now but AP2 does not. Could this not be taken care of with a written plan procedure that dictates whether APs are paid out immediately or not? Such a procedure does not sound inconstant with either quoted section above and the fiduciary would no longer have discretion.
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I have had CPAs try that in the past, but it is plan comp. I always give them the EOB explanation and they back off. EOB current online edition CHAPTER 1A: IMPORTANT DEFINITIONS -PART I - Compensation - Part A - Item 1.g.
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410b PS with 401k Safe Harbor Match - coverage
RatherBeGolfing replied to imchipbrown's topic in Retirement Plans in General
New comp doesn't mean you HAVE to cross test. Allocate based on integration at TWB and test on based on allocation rates rather than cross test.- 11 replies
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- 410b
- profit-sharing
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I agree with Belgarath, the RMD would not trigger a distribution of the remainder of the account even if the document has a "single lumpsum" option only. I think that is a reasonable interpretation of most plan documents and does not need a special provision. Maybe a better way to look at it is that a rollover eligible distribution triggers the "single lumpsum only" requirement?
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Again, you are ignoring the $10,000 you received tax free as a loan...
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Doesn't your scenario leave out the $10,000 loan that you didn't pay taxes on? I have $0 so I take a loan of $10,000 I now have $10,000 I receive income of $50,000 that I pay taxes on I now have $60,000, but I only paid taxes on $50,000 I repay the $10,000 loan with $100 interest I now have $49,900 and I paid taxes on $50,000 When I withdraw that $10,100, I will be taxed twice on $100, and once on $10,000
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Include Participant in Cross-Testing?
RatherBeGolfing replied to mming's topic in Cross-Tested Plans
They count. Just like a participant who used to be eligible but is now excluded counts as a participant if there is an account balance. I can't give you a cite but I know that Janice's book used to point out that such a participant is not included as an active participant in the line by line section. Maybe that is what you remember? -
Include Participant in Cross-Testing?
RatherBeGolfing replied to mming's topic in Cross-Tested Plans
I agree with Mike. They do NOT count for testing until they meet eligibility. The DO count as a participant for 5500 purposes (but not as an active participant)
