truphao

not only recordkeeping fees but assets valuation fees as well, the value has to be reported on Form 5500, right? In addition, the same type of investment has to be offered to other participants to avoid potential BRF issues. Let me throw another wrinkle while we are at it - how are you planning on rolling over the horse into the IRA in case the plan MUST be terminated? I would not touch it either; it has "ain't worth the trouble" 40 feet high neon sign on it.

while most of the plans (especially small ones) are using PY as stability period, the choice of the lookback is really a consulting issue. For example month of September has a tendency to be the "lowest rates" month, if you want to be able to time/plan "things" better, August gives the most flexibility, if you have to process distirbutions in January the month of December is not a good choice, etc.

sorry guys, answering my own silly question. Mathematically it actually does not matter since the answer is the same. (0 + x +y) / 3 * 3/10 is the same as (x + y) / 2 x 2/10; I am assuming everyone agrees that service and comp treatment should be consistent.

the OP says "contributing". If the ER portion of DC has not been contributed yet, then there is a lot of flexibity. If it has been contributed in 2024 then there is flexibility too. Even if the dedcution for 2023 become limuted to 31% It is definitely worth it to do a retro plan from 415 perspective. It is time to get an actuary engaged.

1) no, he can continue with Schedule C 2) yes, he can, he will pay SE tax on all income BEFORE the pension deductions 3) No, it is not too late to set it up retro for 2023 assuming his tax return extension has been filed timely.

counting sevice should be consistent with the average comp calculations. For the 100K answer - yes, for 150K answer no.

sole-prop, activity commenced late in 2021, 2021 Schedule C is negative, 2022 sch C is 150K, 2023 Sch C is 150K. What is my 3 year average comp for 415 limit purposes? Is it 150K or is it 100K? Is there any specifc guidance on that type of situation?

I have no problems having 2 separate plans in the situation you described. The caveat here is that the both plan docs ought to be drafted with care specifying exclusions, eligibility, etc. The only advantage is to simplify F-5500 process and this is iffy by itself (one is for surely to be forgotten if not both). Form 5500-SF is really not a big deal, and there is only one doc required with one plan covering both brothers.

You are not starting a new Plan, you are simply restating the existing Plan to a new Document provider (E-Trade). Please make sure you implement this properly, the penalties for messing this up are very severe.

set up a DB/CB Plan if the Owner is older than his Ee.

I think the restrictions serve the purpose to prohibit circumvating the in-service distributions at early ages.

the lowest safe harbor NRA is still 62.

Thank you again, and I am in agreement again. Was double-checking my understanding.

here is a follow up question. If it were an ERISA plan but only the Owners' benefits are being reduced (no NHCEs are impacted), would the 204(h) Notice be required issued to the Owners only?

John F, thank you for confirming, this is my logic as well but I wanted to make sure I am not overlooking anything impofrtant.

S corp, State of CT, H&W, Husband is 100% Owner of the business, both H and W are receiving W-2. The client wishes to decrease the benefit formula for 2024 (<1,000 hrs as of now). Is 204(h) Notice required? I do not believe so, am I wrong?

Wow, this is really something. Let’s say a clueless (or pretending to be clueless) MD participates in hospital 401k plans and also has a solo 401 from his side-gig. On January 1 he defers full $30,000 as Roth in each plan. He invests both deferrals into the riskiest investment option (or hedging one investment with another one). In plan #1 the investment is worth 3,000 on December 31. In another plan it is worth $300,000. He chooses to treat as excess the first one. Unless I am missing something big, this is a pretty good gambling/hedging/arbitraging option. Please demolish my dirty thoughts.

I second that. This is a huge loss to the retirement benefit practitioners community. Let him rest in peace and condolences to his family.

It has been happening a lot and that is the exact approach we have been taking - just throw all the entities into the Plan, check the CG box and change the adopting ER/main entity to be the most recent one. It requires participation/joinder agreement for other/old entities.

I apologize but I am not following, it was a rough day. Would you, please, elaborate on where do you see CODA?

it is after-tax, not 414(h)

To be able to purchase an additional annuity upon retirement. You can credit either actual ROR for the Trust or the pre-determined rate like 5% for example. It is a design issue, every approach has pros and cons. I do have a municipal entity client that does exactly that, we are the actuaries, plan doc is handled by attorneys.

don't you dare to deprive the sales rep of his commissions! Their job is to sell, and the implementation is your problem to figure out

You follow the plan terms but you need to test the total allocation for the year.

It was a really bad example on my part, here is an attempt #2: DOH = 3/29/2023, DOP = 7/1/2024 (dual entry), but will be statutory excludable until 9/29/2024.