Karen McIver

Are there any resources to find 1099-R's or other proof that a benefit was paid out to a participant? This client doesn't have his old records. Plan was terminated years ago before they became our client.

Years ago we used to send a letter to the IRS when the name of a plan associated to a Trust ID number changes. Is this still required? To what address?

I have a participant that passed away late last year. He's been taking his RMD for years. In 2021 his two children will split the benefit and are rolling their portion of the account into Inherited IRA's. Do we still have to distribute the RMD based on his life expectancy first? I am having trouble finding a definitive answer.

Thank you!

If they file the 5500-sf today they only have a penalty for one day so I wouldn't sweat it. If it comes up, the client should just pay the penalty and move on. The biggest issue is that they will hear from the IRS two-three years from now and it'll take hours to remember what happened.

I am having a hard time finding rules on the two year of service eligibility requirement. I thought you could not have dual entry dates because someone could actually be excluded from the plan for more than two years. Example: Joe is hired 7/15/2018. He meets eligibility 7/15/2020. Does he enter the plan on 1/1/2021 or can there only be one entry date for the beginning of the plan year. Am I confusing rules with 1 year of service and more than 18 months?

It's July and I would like to file a final 5500-EZ for 2019. Do we still just cross out the 18 on the form and put 2019 or is there a preferred method these days?

We have a client who is a 5% owner through attribution and still working. He turned 70-1/2 in 2015. It's a 401k self directed account. For reasons I can't explain, probably because the attribution wasn't coded correctly, he didn't receive RMDs. Based on actual account balances RMDs for 2015, 2016, 2017 and 2018 have now been made without regard to earning or taking into account an offset for expected RMD. The client is leaning toward filing VCP to request waiver of the excise tax. Here are my questions: 1. How should I have calculated the RMD? 2. Should I have taken the expected RMD for the previous year into account when calculating the current RMD? 3. Is there any good examples or explanations on how to prepare the VCP filing? I think I can do it on 14568 and 14568-H but I am not sure. Thanks for any light you can shed on this murky topic!

Thank you

If the plan document states that everyone is in their own group and the contribution is allocated prorate or on an integrated basis do you still have to pass the average benefits test?