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ajustice

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  1. There was an Employer Declaration stating that they were making the 2018 profit sharing contribuiton.
  2. This was a discretionary profit sharing contribution.
  3. Sorry about the dates they did not make their 2018 profit sharing until September 15, 2020.
  4. They filed their 2018 tax return on September 15, 2019. They are a calendar year plan year and calendar year for tax return.
  5. They missed depositing the 2018 profit sharing contribution by the time they filed their 2018 tax return
  6. I have a plan that did not make their 2018 profit sharing contribution until September 15, 2019. Under the correction methods they are allowed to make that contribution but they have to make sure that the 415 limits for 2019 still pass including the 2018 profit sharing amounts. I have one person who terminated in 2018 so does not have any 2019 compensation so their 415 limit would be exceed for 2019. Since this is a new comparability formula with everyone in their own class and their contribution was necessary to pass the test in 2018. Can this money be removed from this participant and put in suspense or reallocated?
  7. I have a highly compensated ineligible participant that deferred into the 401(k) Plan before her entry date. EPCRS and the SCP say you can correct this by a retroactive amendment if the participants are predominately NHCE's. How do I correct it since this is a HCE?
  8. I have an owner who turned 70 1/2 in 2018 and also got a divorce in 2018. The QDRO was not received in our office until 2019. The QDRO has the division date for the accounts on 3/31/2018. The alternate payee will be receiving 100% of the participants account balance. The participant took his RMD for 2018 by December 31, 2018. Does he need to take a 2019 RMD or his account balance zero on 12/31/2018 because the alternate payee is receiving 100% of his account balance? The Alternate payee is not 70 1/2. My thinking is that his account balance is zero and therefore he does not need to take and RMD in 2019.
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