With the passing of the new regs.....

[Guest Why]

How is everyone proceeding, are you adding an additional source to house the deposits posted after 1-1-05? Or are you setting up a new plan and freezing the old?

Either way, what are you doing with December deferrals posted in January? Which bucket or plan will you post this deposit to?

Thanks,

WHY

[GBurns]

Aren't December " deferrals "posted" as December the month of deferral rather than in January when you might actually make the entry? Why would this be "posted" differently from all the other December "payments", expenses and expenditures that are "posted" in your books of accounts as December transactions regardless of which date you actually get around to doing it?

[Guest Why]

GBurns - I agree with you I am always concerned when regulations change the way we do things. I guess my main concern was that I was thinking this through and not missing anything. Thanks for your comments.

Are you setting up new plans or waiting to see the guidance to be published?

Why - why not!

[GBurns]

My focus has for quite a while been on tax consulting and cost reduction strategies for employee health and welfare benefit plans.

However, there has been a growing demand for consulting etc on other plans as well. I expect that this will only accelerate as the dust settles on NQDC, COLI, split dollar and the many other items that have come under attack from the IRS.

As far as NQDC goes, I suggest much reading of the various interpretations and preparation for the Regs. I am taking a wait and see what will be needed, but I need to know what is in current plans now.

[TCWalker]

To be clear, there aren't regs. just the language of AJCA until futher guidance.

Last time I took a poll there was a split of opinion by Benefits, Esqs. on whether they are advising the adoption of new plans now, or to wait.