truphao

The maximum statutory exclusion is 21 & 1 plus 6 months waiting, isn't it? For example, somebody hired 9/29/2022 is statutory excludable until 3/29/2024 although DOP = 1/1/2024.

just want to add that it smells like a document failure; generally those are not eligible for self-correction.

I aslo recommend carefully reviewing the "stable value" contract language with the insurance carrier to see if there are any exceptions applicable to MVA trigger on account of special circumstances (such as merger, benefit payments, etc.)

I am tinkering with doing it by Group. b1 also gives one year, which should be enough.

since I asked I might as well post the answer - these are the options in the Datair PD System:

415 is OK in my case, it has been acounted for already but thank you.

that is exaclty right - have few "good" NHCEs entering the Plan in 2024 and 2025. How does one define an OB in relationship to the past service? Has it ever been presented at NIPA/ASPPA/CCA meetings?

is there any decent presentation on doing the CB Plan with an opening Balance related to prior service?

start-up Combo (CB and PS) Plans with 1/1/2023 effective date. Owner started his business back in 2017. Employees have been hired in 2021 and 2022. Whar are the issues to rely on Accrued-To-Date testing method for this situation to pass 2023 tests?

agreed, I agree with Corey as well regarding the spin-off, it might be the most practical approach.

TPABob, I totally agree, having a separate investment account for Roth is much better. In addition, it allows for more aggressive investment strategy of Roth money which is an additional value from the clinet perspective. The problem is that some clients/advisors are not capable of handling the proper paperwork and moving the money process. Therefore, we have been using one account approach until at least Roth account grows to a meaningfull size.

I am guessing it is an auto-generated notice. You must file 945 if you have to file but you do not. Just ignore it? Paul, the IRS rep will not discuss the plan related issues in details unless the practioners provides a POA

I know it has been discussed on many occasions before and I have searched through the prior threads. But I can't make sense of some elements so I decided to post. We know that one cannot use Form 5305 SEP if "Currently maintain any other qualified retirement plan. This does not prevent you from maintaining another SEP." Q1: Can anyone explain the logic behind these instructions or give a reference to the legislative history/sections of the Code which resulted in such? Q2: These instructions clearly indicate you cannot establish the SEP if DB exists but why do practitioners decide it is prohibited to establish a DB plan if SEP already existed? Q3: What is the meaning of the word maintain" in this context? Is it in the context of "existing" or "deduction"? In other words, is it OK to establish a new DB Plan in 2024 effective for 2023 (when SEP existed) but not take any deductions for contributions made to DB Plan for 2023? Q4: What are the ramifications if a taxpayer ends up having SEP and DB Plan for 2023 (with no deduction is taken for DB contributions for 2023 tax year)? What exactly is the nature of the failure and what are the penalties?

Lou, thank you so much - I am glad I asked since I had that gut feeling I am missing something. I have totally forgot about the 4/15 deadline for adoption, was thinking we would have plenty of time . Amending taxes definitely works but I suspect the prospect will be reluctant, so that might not be the best approach from practical/relationship perspective. I am going after that double-up deduction approach since it gives an extra year of participation for 415 and the prospect is looking to slow down in 4-5 years.

sole-prop, taxes for 2023 have been already filed. I am thinking of still implementing a CB plan retroactively to 1/1/2023, funding it now but taking a full deduction for 2024. Thus, for 2024 there will be doubled-up deduction. Income is very high so the numbers fit in. Am I missing anything here besides the additional level of complexity of decoupling 430 and 404 numbers for a year or two? Had a crazy week so I am afraid I might be overlooking something.

I am not sure I agree with a "separate account" notion. If the plan is designed properly a participant can "purchase" an additional piece of benefit (an annuity) by rolling in his DC money. That additionally purchased benefit is not subject to 415 and it is PBGC protected (if the plan is PBGC covered). So, there might be some numerical leverage involved if/when segment rates go above 5.50%. There is a lot of math there. This is one potential why. Need more info what people are trying to accomplish.

Thank you, Paul, for confirming my understanding. For solo situation it is OK process especially if all deposits are made once a year in one shot.

no, I do not belive I am. You can do MBR in-plan (which I prefer) or outside of the plan to an IRA via in-service distributions. My question relates to potential pitfalls related to maintaining the Roth subaccoint for IN-Plan conversions within the plan.

normally in those situations we recommend establishing a separate subaccount for Roth money, and conversion is done by election with accompanying physical movement of funds into a separate Roth account within the same plan. Is there a problem with keeping all sources (both Roth and non-Roth) within a signle account and the "segregation" being done on the recordkeeping level only. I think it is OK but wanted to hear the wisdom of other practitioners. Are there any considerations I need to be thinking about?

cushion does not exist for a start-up CB plan unless you get funky. Just trying to get my framework together on how to consult for a start-ups in 2024....

I am doing some modelling trying to forecast the segment rates for 2024 EOY valuation. I am getting 4.75/4.96/5.59 for 430 and 5.03/5.27/5.23 for 404. Leaving the technicalities apart, thus my conclusion is that for 2024 the min and max are the same and are driven by 430 rates. This is totally insane, what am I missing?

it is all good for 2024, it is probably too late to do VAT for 2023 given that only contributions made up to January 30th can be considered toward 2023 415 limit.

Thank you all - this gave me enough to formulate my thoughts. Tremendously appreciative, as always.

that is essentially what my question is? They are not partnership, they are not ASG, but are they a CG?

no, each business is owner-only, both H&Q are in professional services but different fields.