Larry Starr

Leave it blank. It does not get a 5500 number (which is what the digits represent).

I get it; and if I had to pick a date before the IRS confirmed what it was, then I would just use the earlier one and not worry about if I was cutting it a day short. No big deal.

My suggestion was some sort of "warning" message at sign in of what the purpose of this system is.

Attached is a sample letter that we fax to two IRS departments to make changes on their master records. It has been modified to take out the specific names and numbers of the client. Meredith (who does this in my office) says it has been a while since she had to do one and won't vouch that the fax numbers are still good, but hopes they are. But it gives you an idea of how to do it, and the good news is that we do get the IRS confirmation from them (as you can see in the fact that we earlier had changed the name before and included the IRS letter acknowledging that prior action). Let me know if anyone has any questions. FAXCOVR IRS Entity Name.pdf

Your timing is perfect; about 2 minutes ago I asked my staff person for the instructions. Will post them shortly.

Peter, How many angels can dance on the head of a pin? ? We will eventually be told by IRS what the actual date is. Can't imagine at this point it matters. Are you planning closings for Sept 23?

Yes, that would be great if there were some sort of warning message to people trying to post as to the intention of the board. I would love not to have individual participant questions.

I'm pretty sure that is not correct. The date of the original owner's death determines which rules apply. Took me a while to get back to this. The fact that a designated bene dies after 2019 doesn't mean the new rules kick in. Here is something just published (I have attached the full text as well): Successor Beneficiary RMDs If the original non-spouse beneficiary dies before the account has been fully distributed, the new inheriting beneficiary is known as a successor beneficiary. If the original account owner died in 2020 or later, the new rule is that the successor beneficiary (regardless of who it is) will have to distribute the remainder of the account within 10 years of the death of the original beneficiary. (Note: within 10 years of the death of the original beneficiary, not 10 years of the death of the original owner.) If the original account owner died in 2019 or prior, successor beneficiaries are subject to the same “old rules” as described above for the original beneficiary, with one exception: the successor beneficiary must continue to take distributions each year as if they were the original beneficiary. By way of illustration, in the example above (with your father, the original owner, dying in 2018) if you were to then die in 2021, leaving the entire IRA to your sister, she would be required to continue taking RMDs from the account according to the exact same schedule you had been taking them, regardless of her own age. So if you hadn’t yet taken your 2021 distribution, she’d have to take it. Her 2022 distribution would be exactly what yours would have been if you were still alive: the 12/31/2021 balance, divided by 50.3. Gmail - Inherited IRA Rules (Updated for 2020 to Reflect SECURE Act and CARES Act) _ Oblivious Investor.pdf

Amen.

Time for all the professionals to stop responding to this individual. Wonderfully said spiritrider!

Wondering what you thought we could do to help if what you have is "entirely too confusing" for you. Seeking another opinion with the same faulty data will not be helpful. If you want to help out this CPA (which could be a good thing), you need to secure the necessary understanding of what actually happened so you can apply all the many rules and processes that we have as our resources.

Hosanna! Are you saying you have a copy of the deferral election signed by your wife back when she was under the impression she was signing up to have deferrals taken out of her paycheck? A simple question actually. If you can confirm you have that actual document, I'd be happy to share with you what *I* think is the next step. I take on cases like this as a consulting job, but not until I know the facts, which is all I am asking of you. And this will be the last time I ask.

What part of "do you have a copy of the deferral election signed by your wife back when she thinks she should have started having money taken out of her payroll check" is unclear?

Once again, not an answer; do YOU have a copy of a signed election form from when your wife thinks she signed up for salary deferrals. That is a yes or no answer. If there is an election and Vanguard has it, you need to have it. You NEED to care what the employer says (right or wrong) if they are contesting your claim.

Does the record keeper actually have copies of a deferral election made by the participant? That is what I am trying to get a simple answer to. You didn't provide us details of what "all the documents" means, and without the deferral election itself, it doesn't mean anything. You might be absolutely right; but until we have at least your verbal agreement that there was an actual deferral election signed and you have a copy, I'm afraid you have no case.

Mike, I definitely saw that. My concern is this participant spouse saying "she's enrolled" and not understanding that an actual deferral election was required and hasn't told us that she did fill out such an election and has copies to prove it. IF that is the case, then she has a case. If that is NOT the case, she is not "enrolled" in anything. I don't trust the language "she's enrolled".

As noted by others, it is not going to be a violation of the adequate security requirement. Nonetheless, it is just plain stupid and I have said that from the day they raised the possibility. As most of you know, I deal almost exclusively with trustee directed pooled asset plans. The plan loans 100% of the participant's account, say $75,000. There is now an asset worth $75,000 as part of the plan. The rest of the assets go DOWN a bit; the participant's account is now LESS THAN $75,000 and a default means the other participants suffer a loss. I have been saying if you have to do it, leave it at 50% OR maybe go as high as 80% (I like 76% even better). In participant directed accounts, it might be a different story, but we don't have loans in 99% of our plans anyway!!! ?

I am in agreement with Ed; I haven't got an idea of what you are talking about or what was actually done.

At this point, compensation is compensation. To NOT match the FFCRA pay, you would have to amend your definition of compensation to exclude that amount, which now brings a whole host of other problems when not using a safe harbor definition of comp. Tell the client NO.

In all these messages, you have not provided the most important information. In order to participate, you wife had to make an election to have a certain amount withheld from her pay and contributed to the plan. Nowhere do you say she did that. We don't know what you mean by "she's enrolled". Very specifically: did she make a valid election of deferral? Did she? How did she do it? Do you have a copy of the deferral election? You obviously knew about the 401(k), but unless she made an election to have withholding, it doesn't happen.

Thank; that will be helpful.

Yes; I talked about the "necessary certification" later in that posting.

Sorry. Not correct. You worked for an IRA custodian and there it is true. For a retirement plan, assume the trustee is also the owner of the employer and the sole participant. Because he is the trustee, he can certainly hold the allowable precious metals in a safe deposit box owned by the trustee as trustee of the plan (I would suggest that it be a separate box from one owned by the individual as an individual). For a retirement plan, it sounds like your company was the trustee. Here is some info: Taking Physical Possession and Storing Solo 401k Precious Metals Precious Metals in bar form including gold, silver, platinum and palladium under the Solo 401k have to be stored with approved depository taking institution such as Delaware Depository Service Company. However, if the Solo 401k trustee is an individual, he or she may safe keep the metal coins for the benefit of the solo 401k at a local bank or credit union. See IRS Private Letter Ruling 200217059. For full list of allowable coins click on allowable coin investments.

I'm still figuring out how we will handle this. I'm thinking that ANY plan level distribution (up to $100k) for any plan reason (termination, working past NRA, disability, etc) SHOULD be treated as a Coronavirus distribution. I'm considering that we won't be adding CDs as an option (unless a client really wants it) but at some near point we change over so that all distributions would be CD tax treatment (assuming participant does his certification). Still working this out in my head. I think we would use our standard distribution forms, but have a special added colored sheet that goes on top describing what to ignore in the package (like the tax notice, the mandatory withholding) and has the necessary certification as an alternative. Ultimately, the plan amendment would reflect this policy. Comments? Also, if anyone has any CD election forms from any of the platforms, it would be helpful if you could post it.

Man of few words......