Jakyasar

Hi Can anyone provide/point me to a link that provides good and simple information on the suspension of benefit rules (or even articles)? Need to check a few things. Thank you

Sorry if this was discussed before as now I have the following situation. A quick follow up on this. Employees are: 100% owner of S-corp Spouse of the owner Children of the owner, all over age 21. 5500-EZ is the way to file. No fidelity bond requirement. Would PBGC coverage still apply?

I guess no takers.

Hi I know of those. My memory might be playing tricks on me as I remember something specific to plan terminations. I will use 2017-56. Thank you for your input.

Hi I am trying to locate a rev-proc (may be a notice) that came out sometime 2016 (if I recall correctly) where it mentioned automatic approval of valuation date for an end-of-year valuation date to either the plan termination date or switch to beginning of year valuation. Just cannot seem to find it but remember it as it was specifically addressing terminating plans. This was something before Rec-Proc 2017-56. Any help would be appreciated. Thank you

Any takers?

Hi A bit confusing myself with a scenario I have not seen before. Defined benefit and profit sharing combo. DB started 2015(HCE only) and PS started 2019. One non-HCE was already in the DB plan for 2018 - year of participation. Another non-HCE is only in the PS plan i.e. excluded for DB categorically. All 3 are participants in the PS plan effective 1/1/2019. DB was amended for HCE only during 2020 using A+B method (A x% of average comp for YOS starting 1/1/2020) and B is AB as of 12/31/2019 without wearaway - standard design. I usually use annual method but for 2020 wanted to look into accrued-to-date method. Assume all data is correct for all past years i.e. I have the correct salary history and the PS plan assets are all correct. Are there issues I need to watch out for the 401a4 testing? Thanks

Mike, this is very generous of you. Thank you

Thank you

Hi Mike Can you please elaborate on your statement "There's also another prong to this calculation predicated on funding Target versus assets"? Thank you

Yes it can be more than 6% but now you have to the 31% test i.e. combined CB/PS (including any safe harbor) cannot exceed 31% of all eligible pay. Again, this is for non-PBGC covered plans. SEP is treated as part of the DC plan deduction and therefore included in the 6% calculations

Hi Lois I saw this but unless I am not seeing/understanding, pension plans not included. I hope someone will correct me. Thank you

Hi Reading Notice 2021-59 and looks like all sole-proprietorship 2020 filings have been extended to May 17th. I did not see anything on C-corps, correct? Also, with this extension, all contribution deadlines have been extended to May 17th as well, correct? Looks like all all states have extended the April 15th deadline except for a few that are pending. There are also a few states that do not have state taxes. Whether a state extends or not, the 2020 contribution deadline is on federal level and extended to May 17th. Is this correct? Thank you

Perfect and thank you

Hi A hypothetical question. Please ignore any testing other than deduction. Assume a DB/DC combo plan. DC is 401k deferral and profit sharing only. Plans are not top heavy and also not covered by PBGC. In the DC plan, have a bunch on HCE's deferring only. To determine the 6% limit (or 31% combo limit), are the HCE's compensation included? One scenario, include them in the DB and another scenario, exclude them from DB. Thank you

Thank you all

Why the 5330 tax? I believe it is Title I but let's see what others will say.

I know it is a stupid question but any takers?

All noted and thank you.

Ok, then what is a reasonable deposit time, assuming cannot be done automatically and requires personal signatures from the sponsor? Just curious on what can be considered a safe harbor in a situation like this? Thank you

Hi Not a 401k expert. I know of only 7 biz days as a safe harbor deposit dates for any deferrals. Looking at a plan where I am told that they only can make one deposit per month i.e. their explanation for "administratively feasible" deposit. The owner travels a lot. The payroll is every 2 weeks. Is this reasonable? I do not think so but wanted to check. It is a small plan with 3 participants. 2 HCE's (owner and spouse) and one non-HCE Thanks

Hi A 401k plan covering owner/spouse and their children. All HCE/key. All receive one paycheck end of year. They received the 2020 salaries end of December 2020 with the deferrals reflected on them. Just found out that, they are depositing the deferrals now. Do they need the VFCP adjustment? I think they do as I see no exception but not a 401k expert. Thank you

Hi C.B. Right on the point as gateway is provided without regard to any allocation requirement under profit sharing requirements. Thank you

Hi Not thinking straight. DB/DC combo - top heavy plans. DC is 3% non-elective safe harbor, PS requires 1000 hours+last day rule DB required 1000 hours for accrual Top heavy requirement is under the DC plan i.e. DB is not required. Gateway is 7.5% i.e. 3% of safe harbor plus 4.5% of PS Participant works 750 hours during the year and employed as of end of year. Does not get a DB accrual though covered. Needs to get 4.5% of PS as must satisfy gateway, correct? Thanks

Thank you for clarifying.