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Posted

more poorly behaving 1 participant plan sponsors.

say plan has 300k in assets.

owner/participant is age 69 and has worked past NRA

pvab = close to 300k

in 2010 owner withdraws 130k (in about 4 payments during 2010) and prepared a 1099R.

no benefit election forms, etc. prepared

plan allows for QJSA to commence at NRA if working or lump sum option

not married and normal form is life annuity.

owner now terminating the plan and will distribute balance.

as far as i see it the 130k withdrawal is a plan operation failure and could disqualify the plan

resulting in potentially loss of corporate deductions and entire pension taxable, etc.

is that a correct interpretation?

Posted

Any chance the plan doc has a loan provision?

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

Posted

the loan provision would only be for as much as 50k.

perhaps if distribution were no more than 50k then presumably it could have been a loan followed by a deemed distribution due to failure to meet requirements.

thanks

i am not looking for a solution as much as i am trying to determine if i have analyzed the violation and potential consequences correctly.

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