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Posted

Company has three owners, A (the father), and B & C (the sons).  Um, had three owners, as A passed away in 2017 (while in RMD status, but I don't think that matters here).  With advice from their financial adviser, B&C chose to keep their portion of their father's money in the plan, so we created beneficiary accounts for them in the plan alongside their regular accounts.

How should we be treating these beneficiary accounts for the purposes of top heavy calculations?  I'd think we count them in both numerator and denominator for 2018, but what about beyond?

Posted

Not sure what you mean by "beneficiary accounts" - are you saying B and C were A's beneficiaries, and they rolled over their distributions into the same plan? If that's the case, then in my opinion you would treat it as unrelated rollover for purposes of the top heavy determination, although some people have other thoughts on this. See this thread from a few months ago.

Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance.

Corey B. Zeller, MSEA, CPC, QPA, QKA
Preferred Pension Planning Corp.
corey@pppc.co

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