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Happy New Year -

A couple questions related to the prior 60 day rollover period and the extended rollover periods for plan loan offsets effective for tax years after 12/31/17.  By way of example, lets say the loan procedures provide that a loan is due and payable in full within 90 days of termination of employment or it is offset.  Participant under age 59-1/2 terminates 1/2/2018 with an outstanding loan that is not in default.  Loan is not repaid in full by 4/2/2018 and the participant has left their money in the Plan.  The loan is technically supposed to be offset on 4/2/2018.  However, TPA/record keeper does not offset the loan in their system until the end of 2018 and a 1099-R is issued to the participant in late January 2019.  Under the prior 60 day rule, when should the participant have "rolled over" the loan offset by making a contribution to an IRA or another employer plan to avoid adverse tax consequences?  Is it within 60 days of 4/2/2018, 60 days from the end of 2018 when the TPA offset in their system or 60 days from receipt of the 1099-R? I assume it is within 60 days of 4/2/2018 unless participant wants to submit a PLR requesting extension of time until receipt of 1099-R because they were unaware that loan was offset...one of the benefits of having this new extended period.  Under the new rules, participant would have until the due date of their tax return (4/15/19), plus extensions, correct? 

Thank you!

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