C. B. Zeller

You only need to test them all together as one big group. Under 414(b), members of a controlled group are treated as a single employer for testing purposes. So if A, B, and C are all the same employer, and C, D, and E are all the same employer, then logically all of A, B, C, D and E must be the same employer.

You only need to test them all together as one big group. Under 414(b), members of a controlled group are treated as a single employer for testing purposes. So if A, B, and C are all the same employer, and C, D, and E are all the same employer, then logically all of A, B, C, D and E must be the same employer.

You only need to test them all together as one big group. Under 414(b), members of a controlled group are treated as a single employer for testing purposes. So if A, B, and C are all the same employer, and C, D, and E are all the same employer, then logically all of A, B, C, D and E must be the same employer.

This particular provision has actually expired:
However, SECURE 2.0 sec. 350 codified essentially the same correction method into law at IRC sec. 414(cc). See also Notice 2024-02 section I, which gives further guidance, including how to apply 414(cc) to terminated participants.

Ta-da, now on BenefitsLink (with Carol's consent):

Inflation-Adjusted Limits on Retirement Plans, Including Maximum Benefits and Contributions (1996-Present)

An IRA can not be part of a qualified plan.
A Roth IRA can not be rolled over into a Roth account in a qualified plan.
Just set up the new account. Do it right.

An IRA can not be part of a qualified plan.
A Roth IRA can not be rolled over into a Roth account in a qualified plan.
Just set up the new account. Do it right.

An IRA can not be part of a qualified plan.
A Roth IRA can not be rolled over into a Roth account in a qualified plan.
Just set up the new account. Do it right.

An IRA can not be part of a qualified plan.
A Roth IRA can not be rolled over into a Roth account in a qualified plan.
Just set up the new account. Do it right.

Stock sale or asset sale?
If asset sale: A still exists as a shell company and the owner(s) of A can sign on behalf of A. The participants can take distributions right after the sale date since they are no longer employees of A.
If stock sale: B is now the sponsor of The Company A 401(k) Plan and has the authority to sign. Participants can not take a distribution until the plan termination date. Termination triggers the successor plan rule and B may not be allowed to maintain a 401(k) plan for 1 year after the distribution date. This is why, with a stock sale, it is important to terminate the seller's plan before the sale date, or be prepared to merge the plans.

Peter's info (as he is clear to remind us, not advice) is thorough and excellent as always.
It sounds like the client is happy with the current tax situation, and ejohnke is just looking to correct the potential disqualifying defect of allowing a distribution that shouldn't have happened. Is that accurate?
If the individual could have had a distributable event, but the plan didn't allow the distribution, could the plan be retroactively amended to permit it? For example, the participant is 60 years old, so amend the plan retroactively to 2025 to permit in-service distributions at age 59-1/2. Problem solved.
If there really is no possible distributable event (don't forget that employer money sources can have much more liberal distribution restrictions than 401(k) deferrals), then you might still be able to get relief for the distribution (and leave the money in the Roth IRA) through VCP.

An IRA can not be part of a qualified plan.
A Roth IRA can not be rolled over into a Roth account in a qualified plan.
Just set up the new account. Do it right.

No, you can't self-correct the initial failure to adopt a written plan. See Rev. Proc. 2021-30 4.01(b) and Notice 2023-43 A-2(1).

Isn't this the technicality on the difference between Nx and N(12)x?

ASC can natively import txt files. Is the file structured in any reasonable way? Have you tried using one of ASC's import wizards or their predefined importer specs, if one exists for the data source you're using?
If you want to take the approach of using code to extract/transform data before loading it into ASC, then a chatbot could probably help you write the code. I'd recommend that you know enough Python (or whatever language) to be able to read and understand the bot's output before relying on it in production. People on the internet seem to like Claude for that kind of task these days, but I can't offer any personal experience.

A mid-year prospective reduction or suspension of the safe harbor contributions for HCEs is addressed in Notice 2020-52. 
III. CLARIFICATION OF REQUIREMENTS FOR REDUCING CONTRIBUTIONS MADE ON BEHALF OF HCEs
As described in section II.B of this notice, contributions made on behalf of HCEs are not included in the definition of safe harbor contributions. Accordingly, a mid-year change that reduces only contributions made on behalf of HCEs is not a reduction or suspension of safe harbor contributions described in §§ 1.401(k)-3(g) and 1.401(m)-3(h). However, a mid-year change that reduces only contributions made on behalf of HCEs would be a mid-year change to a plan’s required safe harbor notice content for purposes of section III.B of Notice 2016-16. Therefore, in order to satisfy the notice and election opportunity conditions of section III.C of Notice 2016-16, which apply generally to changes that affect required safe harbor notice content and are not reductions or suspensions of safe harbor contributions, an updated safe harbor notice and an election opportunity must be provided to HCEs to whom the mid-year change applies, determined as of the date of issuance of the updated safe harbor notice.1
 
https://www.irs.gov/irb/2020-29_IRB#NOT-2020-52

That's correct. The combined deduction limit doesn't apply if the DB plan is covered by PBGC. IRC 404(a)(7)(C)(iv)

That's correct. The combined deduction limit doesn't apply if the DB plan is covered by PBGC. IRC 404(a)(7)(C)(iv)

On Santo Gold’s hypo, isn’t the account balance after the first loan is made still $50,000—that is, $25,000 participant loan receivable + $25,000 other investments?
But wouldn’t ERISA § 408(b)(1) and Internal Revenue Code § 72(p)(2)(A) limit the amount for a second loan?
Consider 29 C.F.R. § 2550.408b-1(f)(2)(i) https://www.ecfr.gov/current/title-29/section-2550.408b-1.
Consider 26 C.F.R. § 1.72(p)-1/Q&A-20 https://www.ecfr.gov/current/title-26/section-1.72(p)-1.
Even before applying the tax Code limits, ERISA § 408(b)(1) limits the outstanding balance of all loans to the participant to more than half the participant’s vested account (measured after the origination of each loan).
On Santo Gold’s hypo, if the participant when applying for a second loan has not yet repaid anything on the first loan, isn’t the second loan $0?

Hoping that Mike Johnson doesn't see his shadow and give us 6 weeks of government shutdown!

Plans limiting pre-tax catch-up contributions for employees not subject to section 414(v)(7). The rules of paragraph (b)(3)(i) of this section also apply to a plan that includes a qualified Roth contribution program and, in accordance with an optional plan term providing for aggregation of wages under § 1.414(v)-2(b)(4)(ii), (b)(4)(iii), or (b)(4)(iv)(A), does not permit pre-tax catch-up contributions for one or more employees who are not subject to section 414(v)(7).
The bolded part makes all the difference here. Normally, you do not aggregate wages from multiple employers to deterimine if an employee is subject to mandatory Roth catch-up - even if the employers are part of a controlled group or otherwise aggregated for other plan purposes. However, the referenced sections provide for optional aggregation of wages if the companies are using common paymaster, are aggregated under 414(b), (c), (m) or (o), or in the year of an asset purchase. If the plan is optionally aggregating wages under one of those provisions, then you may end up with some employees who would not normally be subject to mandatory Roth catch-up, but who are solely because of the aggregation. What the quoted paragraph is saying is that a plan can restrict those employees to Roth catch-up even though strictly speaking they are not subject to 414(v)(7).

Plans limiting pre-tax catch-up contributions for employees not subject to section 414(v)(7). The rules of paragraph (b)(3)(i) of this section also apply to a plan that includes a qualified Roth contribution program and, in accordance with an optional plan term providing for aggregation of wages under § 1.414(v)-2(b)(4)(ii), (b)(4)(iii), or (b)(4)(iv)(A), does not permit pre-tax catch-up contributions for one or more employees who are not subject to section 414(v)(7).
The bolded part makes all the difference here. Normally, you do not aggregate wages from multiple employers to deterimine if an employee is subject to mandatory Roth catch-up - even if the employers are part of a controlled group or otherwise aggregated for other plan purposes. However, the referenced sections provide for optional aggregation of wages if the companies are using common paymaster, are aggregated under 414(b), (c), (m) or (o), or in the year of an asset purchase. If the plan is optionally aggregating wages under one of those provisions, then you may end up with some employees who would not normally be subject to mandatory Roth catch-up, but who are solely because of the aggregation. What the quoted paragraph is saying is that a plan can restrict those employees to Roth catch-up even though strictly speaking they are not subject to 414(v)(7).

Plans limiting pre-tax catch-up contributions for employees not subject to section 414(v)(7). The rules of paragraph (b)(3)(i) of this section also apply to a plan that includes a qualified Roth contribution program and, in accordance with an optional plan term providing for aggregation of wages under § 1.414(v)-2(b)(4)(ii), (b)(4)(iii), or (b)(4)(iv)(A), does not permit pre-tax catch-up contributions for one or more employees who are not subject to section 414(v)(7).
The bolded part makes all the difference here. Normally, you do not aggregate wages from multiple employers to deterimine if an employee is subject to mandatory Roth catch-up - even if the employers are part of a controlled group or otherwise aggregated for other plan purposes. However, the referenced sections provide for optional aggregation of wages if the companies are using common paymaster, are aggregated under 414(b), (c), (m) or (o), or in the year of an asset purchase. If the plan is optionally aggregating wages under one of those provisions, then you may end up with some employees who would not normally be subject to mandatory Roth catch-up, but who are solely because of the aggregation. What the quoted paragraph is saying is that a plan can restrict those employees to Roth catch-up even though strictly speaking they are not subject to 414(v)(7).

As of right now, it looks like the article is running under the title "America’s Booming Solo Workers Embrace $72,000 Tax Shelter"
Besides Form 5500, possible pain points include:
Capturing any non-owner employees who are required to be covered (including long-term part-time employees) Analysis of related employers which could result in a controlled group or affiliated service group With respect to an unincorporated business, calculation of net earned income, both for purposes of limiting contributions to 100% of compensation and deduction of employer contributions to 25% of compensation Applying limitations on distributions Applying mandatory tax withholding on distributions Reporting distributions on Form 1099-R Applying a plan's loan provisions

As of right now, it looks like the article is running under the title "America’s Booming Solo Workers Embrace $72,000 Tax Shelter"
Besides Form 5500, possible pain points include:
Capturing any non-owner employees who are required to be covered (including long-term part-time employees) Analysis of related employers which could result in a controlled group or affiliated service group With respect to an unincorporated business, calculation of net earned income, both for purposes of limiting contributions to 100% of compensation and deduction of employer contributions to 25% of compensation Applying limitations on distributions Applying mandatory tax withholding on distributions Reporting distributions on Form 1099-R Applying a plan's loan provisions