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Chris DeMay

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Everything posted by Chris DeMay

  1. I wasn't aware of the SP rule. Thank you. They are clearly in violation. plan 1 terminated 06/30/21. New Plan effective 07/01. Given they have violated the SP rule, rolled their money into the new plan, how do they fix this?
  2. Client had a solo 401k and terminated it on June 30th. On July 1 they hired there first employee and created a brand new plan giving immediate entry. Client received a 13k profit sharing allocation on the terminated plan. Do we have a coverage or discrimination issue with the new plan?
  3. Hello: first year of employers plan was 2018. The 2018 contribution was as for 70,751.10. Plan sponsor is a sole proprietor. 61k of this was his self employed 401k/sh/and er ps 1750 was his spouses SH and er ps The remaining 8k is for his rank and file sh and er ps. Questions: 1) I assume he goes through VCP to correct the late contributions, correct? 2) How do we impute lost earnings? I would expect to find the market lower today than 10/15/19. 3) Any issues with deductibility? I think we need to amend 2018 return for the contribution and deduct in 2020. 4) any other issues with 404 and 415 by making the 2018 contribution in 2020. The 2019 contribution will be made by the 10/15 due date.
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