Jakyasar

Thank you both for your responses.

2 hypothetical scenarios so making things up: Scenario 1: A QRP receives 105k in excess assets from a DB plan and will allocate in 7 years. It is invested in a 0% interest bearing account. Year 1 must allocate 15k (1/7th of 105k) so end of Year 1 balance is now 90k What are the Year 2 and Year 3 requirements assuming minimum will be allocated Scenario 2: Same as above with the exception it is invested in an account that will have 10% return Year 1 must allocate 15k but now end of Year 1 balance is 99k What are the Year 2 and Year 3 requirements assuming minimum will be allocated? Thanks

If 1000+ hours is already accrued (assuming the plan has 1000+ hour requirement - plz check the document) and there is no last day rule within the MPP, isn't there a 2025 contribution requirement? As Bri said, if to freeze or terminate, 204(h) notice is required. As Cusefan said, best to terminate and start a 403b plan as 401a plan may not be merged/converted into 403b plan, logically speaking. Can you run MPP and 403b concurrently? If yes, must watch for 25% deduction as well as 415(c) limits. Sorry do not remember all the MPP to PSP conversion details from 23+ years ago that was allowed with EGTRRA restatement - fuzzy memory but it was done all the time but possibly before 1000+ hour requirement.

Thank you both for clearing this up.

Hot and humid, not thinking straight. Checking a proposal for a DC/CB combo DC is 401k+SH Match+PS A previously employee claimed to be an HCE turns out to be a NHCE. Let's call him Joe Joe is excluded from CB plan and also gets on no PS under DC plan. 401k deferral generated enough SH match to exceed 3% of salary so top heavy is satisfied. Plugged this into the program and combined testing says Joe does not need to get gateway. Just checking is the program is right.

already done but you think they will not blame you anyway???

100% in agreement, thankfully a CB plan so funding is not affected. I was just looking for another solution that I may have missed/not aware of. Thank you for your comments.

MRC is satisfied which is close to the contribution amount. Increase in the schedule c due to inability to deduct will not affect MRC as it is a CB plan. No other solutions???

Hi Believe it or not, first time for this in recent memory. Sole prop filed their return 2024 on 4/15/2025 with no extension. Despite all warnings, made the pension contribution in May 2025 but took the deduction for 2024. Net c was 350k and the DB contribution was 100k and taken as a deduction on 2024 return. What can/should be done for 2024, if anything?

I am not sure amending the interest after plan terminated would work. also, there is the question of how it would affect the offset calculations.

Thank you for all your comments.

It is covered by PBGC and this is why I was curious on reallocation compliance you were referring to. can you elaborate please? Thank you for your other comments.

Plan document says allocate to the participants Does the proposed reallocation comply with the PBGC rules? - Not sure what you are referring to? Does the proposed reallocation pass IRS nondiscrimination testing? - No method has been determined on but possibly 1% standard formula. No submission for DL for termination that I am told. Thanks

Not my plan but having a discussion about it. Offset DB plan terminated. Due to offset, out of 20 participants, only 2 owners have benefits. all others' benefits are offset by DC plan. Document states, excess is allocated to the plan participants. Questions raised and discussed (asking them as they are): Assuming the excess to be allocated to the participants, do all need to get an allocation? If yes, can there be any offset? Do both owners need to get an allocation or is it possible to give only one owner the additional allocation? Neither owner is at 415 limit. Can a qualified replacement plan (QRP) be set up now, plan provisions be amended for reversion to employer and excess transferred to it? Provisions have been around for more than 5 years. Any other suggestions?

Just saying "yes" in an email should not be enough (nor a proper authorization) as they need to sign a proper form with proper language/declaration permitting your company (not you personally) to file. One of the important declarations is "I understand my signature is available for public viewing" - (for non-ez plans). You want all this on the form that they sign. Every vendor has their own way of providing the esigner form so please look at yours and see what language they have. I would never file on behalf of a client with a "yes" in an email. I want that form signed/dated allowing my firm to file on their behalf but that's me.

If 100X fails, try RR 74-307 rule but keep in mind that it is based on years of participation only, cannot use years of service. When determining the lump sum for 74-307, 415 limit should be adhered to i.e. do not base the lump sum based on a very high mortality table that exceeds 415 lump sum at NRA. This lump sum is based on projected monthly benefit at NRA which can change from year to year. If you continuously reduce the benefits and/or freeze the plan, you will need to recalculate the insurance coverage and make sure that incidental limits are not exceeded. When applying RR 74-307, do not forget the 66.66% rule for whole life and 33.33% for universal/term life. You can certainly flip flop using 100x or RR 74-307, no requirement that it has to be the same method to check. However, as always, please check the plan document language and see what is allowed and what is not. My 2 cents FWIW. FYI, I hate insurance in any pension plan, nothing but trouble and never explained by agents properly and what the consequences are, what do I know.

I love them both but I wish that EOB would have a better search engine. Something I discussed with Sal a long time ago but unfortunately it was not in hands to fix, it was the publisher. Still an issue and not intuitive, may be it is me but I hear from others as well. EOB is far more technical and full of examples, when you can manage to find what you are looking for. ERISApedia has a great layout of the law and sections but you have to pay for all separately which can add up quickly especially if one is on budget. still very well explained and in layman terms. The new DB section is also very good. Just my 2 cents

Hi Bill Thank you. All the best

Hi S-corp has 50/50 2 shareholders - unrelated to each other and no other employees From 2024 EZ instructions Covers only one or more partners (or partners and their spouses) in a business partnership (treating 2% shareholder of an S corporation, as defined in IRC §1372(b), as a partner) Looks like 5500-EZ can be filed, correct?

Hi John Match is over 3% of salary. Thank you for your input.

Combo plan CB/DC DC has SH match (not nonelective 3%) HCE (not owner) is excluded from CB plan. Defers and gets SH match. DC satisfies TH and states only TH with no percentages. HCE TH is satisfied without additional 3% PS allocation, correct? Thanks in advance

Hi Just picked up a PBGC audit for the first time well in over 10 years. Any new developments/things/pointers anyone with recent experience can share? Thanks

I agree with you about the language. DC doc does not state 5% and it also states "for a non-frozen DB plan", it is not required unless 5% is indicated (FIS doc) So, I take it, from what I read and above, for a frozen DB plan i.e. no one accrues a benefit, 3% is the top-heavy. It also states, for all participating in the DC plan only (there are exclusions for DB plan), top heavy is 3%.

Combo plan, top heavy and top heavy provided by DC plan. DC plan has 3% non-elective SH DB frozen but a class of employees are excluded. There will be no =accrual for 2025. The document states TH is provided by DC and nothing else. What is the TH requirement for 2025? 3%?

Isn't fresh start a law for conversions?