Jakyasar

agreed and thank you, you got it spot on.

Participant was 0.3% partner in law firm in 2024. Still working. No ownership in 2025 Turns 73 during 2025. Is he required to take an RMD which would be due 4/1/2026?

When in doubt, have PBGC make the determination (you can check on their website). I have had multiple applications for determination and got different determinations. Depends on the kind of the business as well as professional licenses held by the business owner.

thank you both for your input.

Hi The sponsor terminated the DB plan in 2024 - not sure when the distributions happened - 2024 or 2025 - waiting for info, I did not do the termination and this will be a takeover. The sponsor now decides that termination was a mistake and wants another DB plan. As far as I know, there is no 1 year wait on this situation and can start the new plan in 2025 even if the final distributions happened in 2025 (they did unfortunately and account is closed, no luck there to rescind the termination). Am I forgetting anything? Thanks

Don't forget to check affiliated service group possibility.

Thank you and I agree based on what I read about end of the plan year. 80% comment noted.

This is something I have not had any experience with. Trying to read but not too clear on how and when and what can be done. A very recent takeover plan for 2024, EOY val. Cannot determine the benefits calculated by prior firm and waiting them to explain but not likely by 9/30/2025. 2024 AFTAP was certified at 110% back in September 2024 and prior years have always been over 100% By looking at the possible benefits and nice return on investments, I think the actual AFTAP will be certified well over 100% (based on some conservative calculations). Client already deposited 2024 contribution, nice sum. Small plan with 3 participants. Thinking of generating a range AFTAP for 2025 with at least 100% (based on prior history) and have it certified by 9/30/2025 so that the plan can avoid any restrictions. If the above is doable, when does the actual AFTAP for 2025 needs to be certified or am I wrong that the actual AFTAP has to be certified by 9/30/2025? Thanks

Although I agree with either approach, what if the residual is a considerable amount, say $500 or even $1,000+. No indication of what the small amount. What do you consider a small amount to be defensible?

Aren't' you late for 2022 as it was supposed to be filed by 10/15/2023 unless for 8868 was filed for 6 months extension? The deadline from 2024 instructions, Table 1 4971 - 15th day of the 10th month after the last day of the plan year. I am filing for my client by 10/15/2025 for 2024 deficiency on 2024 form.

For more fun stories on really screwed up situations, did you see today' Erisapedia webinar " best of the worst in 2025" presented by Ferencyz Group? You cannot make up some of these stories. It makes the problem above a breeze between providing missed benefits and missed filings

My first missed 9/15 deadline for MRC in well over 20 years. I want to make sure I understand what needs to be done per my research. Client did not make the MRC by today, around 30k I checked 5330 and looks like it is section 4971a related. Subject to 10% penalty - not sure when needs to be paid but will instruct as soon as filed. According to instructions, 5330 is due by 10/15 and no extension was required. It still needs to be paid by 12/31/2025 and if not then IRS could impose penalty up to 100% for subsequent years. I have to do interest adjustment based on the date they will make the deposit (if they will) Am I correct on all above?

Thank you for your input. Still researching but not looking good.

Hi A general question as researching it. Have you ever switched from a BOY to an EOY val? I am aware of the other way around with automatic approval. If you have, can you share how managed it, if possible? Thanks

Agree but dealing with different circumstances