acm_acm

I'm not an expert on this, but I would think you measure the total benefit obligation, FT, etc. and then treat the buy-in annuity as a plan asset valued at cash/surrender value.

Can't one use a different discounting method for the IRS versus PBGC purposes? If so, the IRS has no say over the discounting method used for determining PBGC premiums, filings, etc.

One thing to consider when documenting the loan provision is that Moody's publishes lots of "bond rates". It would be best to precise about which rate will be used.

I think the point is that one can exclude a class of employees (drivers, sales, etc.) and then neither FTers or LTPTers in that class would enter the plan.

Take a look at ERISA section 510. I think that would apply here.

I used to live in PA and have posited* that a lump sum shouldn't be taxable in PA, except for the amounts in excess of the contributions made becaue they were previously taxed. I seriously doubt many people know this and/or have the records to establish the "cost basis". * Most colleagues disagreed, but I think I am right on this.

Not sure of the impact here, but remember that 5th anniversary of participation does not mean 5 years of participation. They could be different if there is an hours requirement for a year of participation. Said another way, once some becomes a participant in a plan, their NRA is supposed to be known and should not change based on hours worked after that time.

If one is saying that LTPTers would come in based on 500 hours, even if their class (drivers, sales, division, etc.) is otherwise excluded, then all of the FTers in that class would have to come in for deferrals as well. I would think if a group is excluded (not just based on hours) then the LTPTers in that would be excluded no matter what their hours are.

Agree. I think it's true because death benefits don't vest. Anything beyond the QJSA can be taken away.

Plus, there have likely been contributions made since the separation/divorce date. Those would need to be backed out, no?

Are you sure the person terminated? PRN is hospital/medical-speak for "as needed". An employee marked as such works less than parttime but hasn't been terminated, although they could have 0 hours for a year, I guess. Would that be a termination for plan purposes? It's not clear to me.

Red flag number 2.

If it were my HSA, I would file/amend my 2022 taxes with the deduction for 2022 and treat the "2023" instruction as a scrivener's error.

Ask the service provider if they are willing to become a fiduciary to the plan for such a decision.

People, including many politicians, are conflating a default due to hit the debt limit versus a government shutdown due to a delay in passing a budget. We've dealt with the latter before and it does cause some problems. If the former occurs, not getting IRS/DOL guidance will the least of our problems.

Euphemism of the year.

Fred Reish to the rescue: The SECURE Act 2.0: The Most Impactful Provisions (#4–Optional Treatment of Employer Contributions as Roth Contributions) - Fred Reish

To keep things on an equal footing I would expect the employer takes a deduction for the Roth contribution and the employee would be taxed on the amount of the contribution as if they had been paid that amount. It should be the same as if the employee gets paid by the employer and then the employee made their own Roth contribution.

Maybe someone should spend a buck for a copier/scanner.

One more thing...it's an amicable divorce...for now.

$3???

You still have the problem just with lower stakes, except in the case cited where the entire beneficiary designation was thrown out. I.e., with two decimal places allowed for the percentage, you're still a stuck with three 33.33% designations (risking invalidation) or somebody gets 33.34%.

Regardless of what the plan document says, why would one *not* go ahead and submit new paperwork???

I'm not sure why one would find this surprising or an issue.

Is there any downside to getting a TIN? If no, then why not get one always?