RatherBeGolfing

Its plan design. The plan is safe harbor regardless of any actual deferrals and match contributions.

100% agree.

Yes. Its not "could file an EZ", its required to file an EZ. If you are required to file on an EZ, you cannot file an SF. Almost. You have to mark it as "First return/report". And be prepared that you could receive a letter from DOL or IRS asking why the first return does not line up with the plan effective date. No big deal, you just tell them you filed EZ before. Is the plan covered by Title I?

At least we should get Secure 2.0 technical Corrections now that there is something to attach it to...

SF as long as they meet the normal requirements for a 5500-SF over a 5500 with Schedule I, such as eligible assets.

Great point Ilene!

This happens all the time. I have never had the IRS follow up on a final EZ with $0 BOY assets.

That is how I read 8(ii) as well.

So no other adjustments in the AA or BPD? What is the difference between W-2 + elective deferrals? I bet its 125 pre-tax deductions...

RTFD. I'm sure the document says more than just W-2 comp. All document provisions regarding comp matter, not just W-2, 415, etc.

Nah, I don't see the point to be honest.

I agree with @Bill Presson as far as credential is concerned, but I am not aware of a requirement to have the prior credential to take the exam. In other words, you can take the exam before you have the QKC designation, but you can't apply for QPA without having met QPC. I took the exams out of order before there was a QKC designation, but this was back in the hunter-gatherer days...

Im aware, I was pointing out that the DOLs position is that you have to file with DOL, not IRS, if you want to use the calculator. The OP stated " I know some will say you cannot use the DOL calculator unless you file with the IRS", which is incorrect.

This is the answer. And it is impossible for us to guess if earnings should be considered without knowing what the DRO says...

The DOL says you cannot use the calculator unless you file VFCP (DOL not IRS).

Let us know when the DOL reaches out... 😟

If you need the additional 2 months for the SAR, amend the 5500 and check the box

I agree.

I have used FTWilliam, Relius/FIS, Datair, and ASC. Relius/FIS has the most bells and whistles, but I found that we simply didn't use 90% of the features. Also, the system isnt wasn't that user friendly. ASC is decent but clunky. Support staff is great. FTW is very user friendly, and the modules are integrated. They are constantly adding new features. Lacks some options on the 403b side. Great support staff. I prefer FTW, but the details of your practice will dictate what the best fit is for you. All three are better than Datair in my opinion.

This.

Many of the S2.0 summaries and webinars have referred to it as testing separately. I think that's where alot of the confusion is coming from.

As far as amendments go, I think most of the providers have been clear, absent guidance that would allow us to treat them as separate catch-ups, they are treated the same. I would not expect a provider to draft the S2.0 amendment any other way. Restatements are a different animal. You can draft the C4 document aggressively even without guidance and let the IRS tell you Yay/Nay.

ASC has taken the same position. Absent guidance permitting us to treat 60-63CU separate from regular CU, if the document allows for CU, the 60-63CU limits are automatically applied.

Looks very straightforward to me. You use the K-1 for ABC LLP. You don't include comp from unrelated businesses.

I agree. The startup credit references NHCEs, but the contribution credit references "employees making less than $100,000". As far as I can recall, owner-employees making less than $100,000 are not treated any different. The ACA credit of $500 has no NHCE or income restriction, and is available for all plans including one participant owner only plans.