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Showing results for tags 'Eligibility'.
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Hi all! The answer to this may be black and white and I apologize in advance if it has been asked before (I did my due diligence searching for the answer on here prior to posting) Basic info: 1 HCE, 13 NHCEs, multiple contrib allocation groups all of which get a contribution (no zeros), last day employment requirement so all terminees didn't get an allocation Plan passes ABPT but fails 410(b) ratio percentage at 60%. I understand that the plan can pass coverage with ABPT only, given "Reasonable Classification" was utilized in assigning allocation groups. Given the following excerpt, I would say it's okay to skip the 410(b), however one issue is not clear to me: Is giving a zero allocation to terminees due to the last day employment provision of the plan, not make a "Reasonable Classification" thus requiring us to pass the ratio test?? Thank you.
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I am an ERPA representing three plans for a very small professional group. The first two plans (a defined benefit and a profit sharing) terminated and the participants were paid out. The owner was unable to liquidate the remainder of the assets and ended up establishing a 0% money purchase plan to hold those assets. The eligibility for the money purchase plan was limited to the owner, on the basis that no other contributions would be coming in, so why subject it to SAR's and the like. An important point is that the distributions to the staff had already been made at the time the money purchase plan was established. Now all three plans are being audited by the IRS, and they have raised the question of whether the eligibility restriction on the money purchase plan violates nondiscrimination in benefits, rights and features. Has anyone had any experience with this kind of situation? Any thoughts? Dog
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401k eligibility protected if going from full time to intern
Guest posted a topic in Using the Message Boards (a.k.a. Forums)
Plan has no eligiblity requirement for deferrals. Entry is date of hire. Plan excludes interns from participation. If regular full time employee becomes intern, are they still eligible to defer?
