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lisan1025

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  1. I have a 401k plan that is TOP HEAVY and makes a PS contribution (new comparability). The Service Requirement is 1 year, 1000 hrs, age 19 to enter the 401k plan but for the Profit Sharing has a Age 21 requirement. I have a NHCE (non-highly compensated employee) that is age 20 so they are entitled to the 3% Top Heavy Contribution, but the client wants to give him a 5% contribution since he is giving all other NHCEs 5% for the Profit Sharing. Can I do this? I am just concerned about the age requirement.
  2. We have a plan with an effective date of 1/1/2020 but the plan didn't start contributing until March of 2021 and they are not going to make any Contributions for 2020 so they'll have NO Assets. I believe we still need to file a Form 5500-SF just putting zeros in the financials? Also since nobody has an account balance under 5c on the 5500-SF I assume I put 0 (zero). Client does not want to change the effective date to 1/1/21 which was suggested.
  3. I have a off-calendar plan 9/30/19 pye. They started contributing a Match (100% up to 1% compensation) per pay on 4/1/19. Their Plan Document is a discretionary ER Match & the Period of determination is the Plan Year. I provided the client with a Match Calculation using Plan year compensation (not 1/2 year) and they do not feel they should have to pay the true-up. Is there anyway around this? I don't think there is because the document indicates plan year compensation not "per pay or 1/2 year compensation, etc.".
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