Jakyasar

I thought exclusion by name was a BRF issue and not considered a reasonable classification!! I would have written as any HCE not an owner is excluded.

Keep in mind that if you have an eligible payroll large enough, 31% test may allow you to make a DC plan contribution (including all employer portion i.e. all match and PS) well in excess of 6%, all depends on the CB contribution level.

Hi This may have been discussed before but cannot remember/locate and having a slow day today (mentally and smoke is coming out my head). I have been trying to find material for the following situation. Existing DC plan, current participants are past age 65 (NRA) Starting a new DB plan for 2025 which will have NRA 65 with 5 YOP i.e. if someone is currently age 67, NRA is 72. I have 3 participants all past 65 with different ages. Currently 66, 67 and 68. For DB, NRA would be 71, 72 and 73 (they are all past NRA under DC). What ages am I testing them for combined plans?

Corey, tx for your comments. No one worked 1000+ hours

Friday afternoon, no brain activity as usual. Combo CB/DC. CG with ABC corp and XYZ corp ABC sponsors both plans and XYZ is an adopting employer for DC plan only DC is 401k with SH match CB excludes all XYZ employees. All ABC employees participate in both plans and get PS allocation as well. None of the XYZ employees defer and none get any PS allocation either (401k/SH has 3 months and PS has 12 months+1000 hours). None of the XYZ employees work 1000 hours but all eligible for deferral+SH and since no one defers, no one get SH thus T/H is satisfied. ABC eligible compensation is 500k and XYZ eligible compensation is 100k Need to use 31% rule for deduction. Do I use 500k or 600k? Thanks

Thank you for clarifying

Following up on this Same owner, turned 73 in 2025, terminated 12/31/2025 and will take distribution in 2026, when is the RMD due?

Isn't one advantage signing after 12/31 not filing 5500 form? Actuarial certifications still need to be done For example (extreme one): S-corp (with employees) decides to start one on 9/14, signs and funds on 9/15. If wanted to file 5500 form, has to file on 9/15 (special extension) as no 5558 to extend to 10/15. Of course, it is assumed that s-corp tax filing is on extension. Full disclosure, not a fan of above but happened once or twice😁 CuseFan has made good points. But more and more I think and encourage, the clients should start the plans after year end as the census data would be final and available and also allow a better design than making one up during the year as census changes all the time. Just saying it.

I have had audits in the past, never this long. I am aware of the personnel changes at PBGC, especially with legal department, so nothing to do but wait. Thank you for your input.

Hi A plan of mine was picked by PBGC for audit and all information was provided 6 months ago. I have not heard from them at all since then. sometimes no news is good news but here I am getting a bit worried that I have not heard anything. Between all governmental firings as well as shutdown, does anyone have an experience similar to mine? Thanks

My current provider for both val and 5500 programs had informed me of a 10% jump in monthly fees which I find a bit too high (I have been using them for 30+ years). I think I need to look into a more modern and 21st century system. I use it primarily for CB/DB and combo plans and need simple DC as well (I do not deal with RKs) as good testing system. I would appreciate your experiences with other systems (except for Relius). Thank you.

Pam, thank you for your input and comments.

This is simply a general discussion to make sure I understand the concept properly. The question I am asking and trying to confirm my understanding: the Roth catch up is solely based on lookback salary regardless of ownership, salary is based on w-2 box 3. Looks like sole props and partners with k-1's are exempt from this. So, per my example above and my understanding, the owner who makes 50k in salary does not need Roth catch up i.e. normal catch up. One more thing, as explained by a friend, the plan needs to have Roth provisions in place before the first Roith catch up contribution. Any comments/corrections/missed information?

Hi As not being a DC person and dealing with very few DC plans, I have a really stupid question as I could not find anything on it. Owner only plan, owner (over 50 years old) makes 50k in w-2 and makes full deferral plus catch up. They are required to have Roth catch up, correct? The plan also needs to be amended to provide Roth deferrals/catch up as well by 1/1/2026, correct? Sorry if this was asked before.

agreed and thank you, you got it spot on.