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ASFESQ

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  1. Last year, someone was generous enough to post the 12/31/2021 actuarial equivalents for a J/S and an individual life annuity for an account balance at age 67. I was wondering if anyone would do the same for 12/31/2022?
  2. What's the basis for putting it back in the plan? I don't think you can rollover a distribution to the same plan. Otherwise you could take out as much as you are entitled to every 59 days, redeposit it and to it again. More egregious than "cascading rollovers" looking for additional plans.
  3. There are advantages to having insurance in a small plan. That discussion aside, further research seems to support the transfer of a policy to the plan as permissible. See Rev. Rul. 73-338.
  4. Client wants to transfer a whole life policy on his life to a profit sharing plan in which he is a participant. There is a PTE which allows the transfer subject to certain requirements dealing with value. Assume that is not at issue and that the ownership of the policy can be either personal or corporate. Can he make it as an in kind contribution equal to the CSV? If the policy has no CSV, can it be transferred unilaterally? If it is transferred, do the transfer for value rules require that the portion of the Plan's death benefit attributable to the insurance policy be treated as income?
  5. But the definition of employee does. See instructions to 5500 EZ. Exclusions: "2 . 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)." §1372(b) references §318.
  6. Why isn't there attribution under 318?
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