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Found 4 results

  1. My client (a divorce lawyer) asked me to write a QDRO for their client who has a solo-401k plan containing real property. I advised a plan audit is needed because of entwined interests in the real property, and entanglements with other real properties that are not plan assets (and are in another state), as I'm not going to write a QDRO for that client until those interests are sorted and all cards are on the table. So, I'm seeking recommendations for auditors with experience with solo 401ks owning real property in multiple jurisdictions. Washington State or Virginia licensure may be required. Please send me a message on-platform if you have any names to offer, thanks.
  2. A 401k plan is on a calendar year and ceases contributions in March. However, the effective date of the termination is in July. Which date is used to determine the prorated 415 limit? If the employer had already ceased contributions with the intention to terminate, but did not make the effective date until several months after, aren't they essentially increasing the contributions allowed by the prorated 415 limit? Any guidance is appreciated!
  3. Facts: Employer has a 6/30 fiscal year and would like to install a SH 401k for the coming 6/30/2019 Fiscal Year end. In order to be a Safe Harbor plan for this year, it must be in place no later than 3/31. For 2018 the employer provided a SIMPLE plan. The 2018 employer contributions are to be deducted on the 6/30/2019 fiscal year return (as is required by SIMPLE plan rules of deduction -- cal year ending within the fiscal year provided contributed by due date of Fed return (incl exts)). Questions: Is this employer permitted to establish a new Safe Harbor 401k Plan (incl PS provisions) for its FY ending 6/30/2019 with a Plan Effective Date of 7/1/2018, thus full dollar limitations? Or, must it delay the effective date to 1/1/2019 since it had a SIMPLE thru 12/31/2018 (pro-rated limitations)? Thank you
  4. The 401k SHPSP provides for pre-tax deferrals, SHM, PS and Davis Bacon contributions. All sources are 100% immediately vested, with the exception of the PS component. The Davis Bacon contributions are used to offset the employer discretionary contributions (i.e. PS), and included in the general testing,etc, In order to be able to count the DB contributions and avoid annualization rules, does the PS component needs to be 100% vested also? Thank you!
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