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Message Boards Digest

November 28, 2017

Here are the most recently added topics on the BenefitsLink Message Boards:

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Tom created a topic in Retirement Plans in General

Shared Employees

We have a doctor client who shares employees with other doctors. The 6 doctors operate under different tax entities. One doctor pays all the employees through his payroll for convenience. Their accountant charges the other 5 doctors their share of wages. The accountant tracks hours worked for each physician and allocates compensation accordingly. Some employees work for all and some only for one doctor or several doctors. So at the end of the year we get a census showing hours/wages for each physician and a total. I understand the very old regulations for shared employees are still in place which say you look at the total hours for all employers in determining the 1000 hours threshold and then allocate the employer contribution only on the wages paid applicable to a particular physician's business. My concern of course is -- would the IRS support their own regs in this case? The good thing is that only 1 of 6 physicians even has a plan so in looking at the group as a whole, coverage likely would pass. I believe the group has a common marketing name and phone number. I don't know how they bill insurance -- I hope and fully expect that to be filed under each of their separate business EINs. Thoughts? And thank you in advance. Tom
Number of replies posted  1 reply      Number of times viewed  42 views      Add Reply
 
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WhatsESUP created a topic in Distributions and Loans, Other than QDROs

Hardship Distribution Request for Funeral Expenses of Participant's Sister

A participant is requesting a hardship distribution for funeral costs for a sister. The sister did not live with the participant and was not claimed as a dependent on the participant's tax return. What does the plan sponsor have to do to verify that the participant's sister is a dependent? Thanks!
Number of replies posted  2 replies      Number of times viewed  41 views      Add Reply
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Janie created a topic in 401(k) Plans

401k RMD for surviving spouse, sole beneficiary

Husband died in 2016 at age 76. Made RMD in 2016 after death; Wife stayed in 401K plan but just had name changed from husband to wife (Age 72 at time of husbands death.) Thought the transfer in wifes name would allow wife to continue to use the Uniform Life Table since wife was only beneficiary. Principal Group handles the Plan and they are insisting that wife must take it using Single Life Expectancy. I have been trying to get someone to listen to me that the Uniform Life Table should be used. It appears that once the first RMD has been made as a "beneficiary" vs. surviving spouse, the wife will be stuck with the single life expectancy which is undesirable in this situation. It appears that wife has no choice in 2017 RMD. If the 401K is rolled over to an IRA, what table will be used in the IRA and can the IRA be treated as "wifes own"? Please help….I am not a professional…just a fan of the website.
Number of replies posted  3 replies      Number of times viewed  30 views      Add Reply
Author's photo

goldtpa created a topic in Operating a TPA or Consulting Firm

Deconversion Fee

On a client who terminates and switches TPA, I am curious as to how many TPAs are charging a deconversion fee or a fee to send copies of prior documents to new TPA.
Number of replies posted  6 replies      Number of times viewed  37 views      Add Reply
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Belgarath created a topic in Cross-Tested Plans

Grouping of rates/EBR's under 1.401(a)(4)-(2) and (3)

The regulations give mathematical certainty as to what constitutes an acceptable "range." However, there is that annoying caveat that says as long as the allocation/accrual rates of the HCE's within the range cannot generally be significantly higher than the allocation/accrual rates of the NHCE's within the range. I've always found this troubling. What is "significantly higher" (especially since the range is limited anyway) - is there any guidance on this? Thanks. Editing typo...
Number of replies posted  4 replies      Number of times viewed  24 views      Add Reply
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Below Ground created a topic in Distributions and Loans, Other than QDROs

Living Trust as Beneficiary

Participant dies at age 81. Was not Key or HCE. Spouse had already died. 3 Adult Children, who are named as Contingent Beneficiaries. Primary Beneficiary is named as Living Trust establish with the Participant's name. Since Living Trusts are something I have zero experience with any suggestions, comments or advice on how to process this death benefit will be greatly appreciated. Thanks!
Number of replies posted  1 reply      Number of times viewed  14 views      Add Reply
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