Medusa Posted March 6, 2009 Posted March 6, 2009 Hello all, Some of our clients pay their TPA fees directly (we are the TPA), with the exception of distribution fees. If a participant's vested account balance is $500, and the distribution fee is $100, the participant receives $400 and that is what is reported on their 1099R. Now, the investment platforms don't typically break out that $100 in their annual reports. In the foregoing situation, they would show a distribution of $500. The question is whether the $100 fee is a plan expense or a participant expense. I feel that because the participant never sees the money, nor does the taxable amount include the $100, it is really a plan expense and should be reported as such on the Schedule I. Does anyone feel that this doesn't need to be reflected as a plan expense? All points of view welcome! Also posting this in Distribution board. Medusa
SheilaD Posted March 6, 2009 Posted March 6, 2009 Hello all,Some of our clients pay their TPA fees directly (we are the TPA), with the exception of distribution fees. If a participant's vested account balance is $500, and the distribution fee is $100, the participant receives $400 and that is what is reported on their 1099R. Now, the investment platforms don't typically break out that $100 in their annual reports. In the foregoing situation, they would show a distribution of $500. The question is whether the $100 fee is a plan expense or a participant expense. I feel that because the participant never sees the money, nor does the taxable amount include the $100, it is really a plan expense and should be reported as such on the Schedule I. Does anyone feel that this doesn't need to be reflected as a plan expense? All points of view welcome! Also posting this in Distribution board. Medusa I agree with you and would show it as a plan expense.
Below Ground Posted March 6, 2009 Posted March 6, 2009 Count one more for "plan expense". I have listed fees like this for about 24 years. Gone through many 5500 audits. Never a problem. Having braved the blizzard, I take a moment to contemplate the meaning of life. Should I really be riding in such cold? Why are my goggles covered with a thin layer of ice? Will this effect coverage testing? QPA, QKA
Bird Posted March 6, 2009 Posted March 6, 2009 Agree, it's an expense. Probably widely misreported, especially if it takes extra effort to find. Ed Snyder
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