plan term, nhce liquidated but pending s/h deposit

2 person plan - owner and nhce - terminated early last year due to business closure and all final comp was provided for safe harbor contribution which was deposited, and nhce account liquidated. owner account still exists so the plan itself still has assets.

with the close of the year, accountant has determined there was additional pay that did not receive the s/h contribution.

with no account to deposit to, what would the best way be to make up the s/h contribution of about $50?

Reopen the account?

Send a check for $40 to the former EE and $10 to the IRS and send the proper 1099 for 2018?

I would give serious thought to 2nd choice.  When was the dist form signed by NHCE?  Can you still use it as the basis of how to pay the person?  I forget is a form good for 180 days?  Too small dollars to set up an account and send forms if it can be avoided.  

Well, you would have to send a form, as it's probably under the cashout.

Also, since it's under $200 you don't even have to withhold!

Keep copies in the plan file of everything and move on.

Is ignoring it completely a possibility under EPCRS guidelines?  (This wouldn't resolve a Title I claim by the employee, but c'mon . . . .) 

well, 'final' comp has been updated again.  remaining safe harbor amount is just under $500.

former recordkeeper will not make it easy to reopen account for this (owner's account is elsewhere)

paperwork and original final distribution are over 180 days ago.

based on your comments, perhaps the following solution:

• resend distribution paperwork
• pay check from prior owner to ira (will not reflect as coming from a plan)
• create 1099-r from plan

if ira cannot accept, then I guess paying directly to participant with 20% withholding and 1099-R (highlighting how it can be deposited into IRA)