SSRRS

Thank you very much Bill.Presson, David Rigby, shERPA, and Effen for your insights and time. As usual, your knowledge is much apprec iated. It seems that the new actuary is not aware of the outstanding fees.

Hi, A DB client left with owing four years or so in annual admin. fees. (long time client, who kept saying each year, come on, after all these years you don't trust that I will pay you?). The new actuary is requesting a copy of the last valution report. While aware that per the code of professional conduct files cannot be held back due to outstanding fees, however, does this apply even to a val report that was previously provided to the client. Meaning is it permitted to say that being that this was previously provided to the client, if the client requests an additional copy he will first have to pay the outstanding fees ? Thank you.

Thank you David for your advice and time. As usual, you managed to set things straight in a clear concise way. Sometimes I do get bogged down, getting to analytical. Thank you, and may you be safe.

Hi, A DB Plan has been owner only (owner and wife) for approx. past ten years, but kept filing PBGC until now (showing only 2 participants each year). This year did not file and when contacted by PBGC it was explained to the agent that the plan is owner only since 2008 and a copy of the 5500 EZ was given to the PBGC (showing that it's an owner only plan). The agent agreed that the plan.is not covered anymore and emailed a convoluted form to fill out so that the plan can be removed from PBGC records. 1. The form has a box to check to confirm that a copy of plan document is being included with the form...why do they want/need a copy of the plan document for this purpose?..2. They ask that if the spouse of the owner is a plan participant, was she an employee, director, or manager? Why is this relevant, doesn't attribution say that the spouse is an owner as well? This is an INC. There is an attribution exception of non involvement. This means that the spouse has no involvement in the other spouse's business. However, in this case, since the wife is on the plan that means she is involved in her husband's business, as you can only be a plan participant if you are an employee of the sponsor. 3. So attribution should say that the wife is an owner? Thank you for any insight or ideas in regard to the best way to proceed with this.

Thank you very much Jakyasar, C.B. Zeller, and RatherBeGolfing. I hope you all , and everyone as well, stays safe.

Since Many/all are working remotely will the fye 6/19 5500s that were on extension until 4/15 be included in the new extension? It's hard to understand if it is not further extended. Thank you.

Hi, The ppp loans cover retirement plan contributions. While it is highly unlikely, does this by any chance include DB Plan contributions? Thank you.

Thank you Lou S. and Mike Preston for the detailed and informative information. I hope you all are/will stay ok and safe.

Hi, Is this allowed (take DB RMD based on account balance method) only if the RMD is his first, or is it allowed even in a case where it is not the First year that he must take an RMD? Meaning he is terminating the DB plan (owner only plan) and taking a lump sum rollover to an.IRA. Can he take his RMD prior to rolling to the IRA based on the DC method even though he has taken in previous years an RMD in the normal DB annuity form? Thank you.

Thank you!

XTitan, thank you very much. Does this mean that 1st RMD that was defered to 4 1 2020 is included in the temporary waiver of RMD (the language is a bit confusing)?

ESOP Guy, thank you. I am just wondering, true the RMD due by 4/1/2020 is for the 2019 year (1st RMD that was allowed to be deferred until 4/1). However, it was allowed to be deferred until now in 2020. Therefore, isn't it quite reasonable to claim that it was not possible to get it done due to the current situation?

C.B. Zełler and ESOPMomma, thank you so much. Especially during these times your knowledge and support is really appreciated. Although, the main and amost only important thing right now, is that you and everyone should be and remain healthy.

Hi, I hope everyone is/ and will be safe and healthy. I see there is talk about extension for the restatements. Is there any chance that the requirement to take the first RMD by April 1st, will be extended to a later date? Thank you.

Mike, thank you very much.

Hi, In an S-Corp, owner only DB Plan , the owner did not take a w2 for 2019. The benefits are based on the 3 highest consecutive years of salary (over entire career). Can a contribution be made for 2019 since a 3 year salary average was established from prior years?

C.B. Zeller. thank you very much for your help. The instructions for the 2848 state that to sign as an unenrolled return preparer you must have a valid Annual Filing Season Program Record of Completion for the year or years in which the representation occurs. Does this apply for a preparer of form 5500?

Based on the above, if a PS Plan is being audited by the IRS can a TPA, with no credentials such as enrolled agent etc., still be listed by the client on the 2848, as the one that will send the IRS agent the requested information and correspond with the agent during the audit, or must the TPA have some credentials to be allowed to be the POA? Thank you.

Cloudy are you referring to the a26 exemption for PBGC Plans that are frozen and underfunded.

Thank you David. A (belated) Happy New Year.

Hi, Is there any basis in using a discount rate for the FASB that is determined by taking the effective rate of the 430 HATFA segment Rates (minimum contribution rates---from the Val) ie 5.64%, and the effective rate of the 404 seg. rates (max contribution rates) ie 3.99%, and the average of the two effective rates is the discount rate for the FASB? Thank you for any insights/opinions on this matter.

Thank you very much Sellarsian and A Happy and Healthy New Year..Yes, that is what I was asking (as the regs limit the % to be used for the J&S based on the age difference batten the participant and the non spouse survivor and therefore was asking if the COLA was limited as well). If the participant is 70 and the non spouse survivor is 20 and using a 50% J&S WITH 120 month certain can a COLA up to 4.99% be used? What if the participant is 70 and the survivor is 47 and using 67% J&S WITH 120 months-can a COLA UP TO 4.99% be used? -----I know there is a table that limits the J&S % based on the age difference between the participant and the survivor, however, I'm unaware of a table that shows the COLA that can be used (if any) based on the age difference between the participant and the non spouse survivor. THANK you very much.

To clarify my question above: A DB Plan was set up to allow for an option of J&S, and non spouse survivor allowed, combined with a years certain with up to a 4.99% COLA. Question: is this COLA allowed even when the survivor of the J&S is a non spouse? Thank you for any insights.

Hi, A DB plan offers benefit option of Joint and Survivor combined with a years certain annuity. The J&S can use non spouse as the survivor (and of course there is a maximum % allowed based on the age difference between participant and the non spouse survivor). The plan offers cost of living (COLA) increases as well (up to 4.99%)----the benefit at RMD age/ret. is reduced due to the future increases of 4.99% per year. Is this COLA allowed to be used in a case where you are using a non spouse for the J&S? Thank you

Thank.you very much, David and HoJo. Both of your efficient responses will be of help (depending on the case).