7-31-17 year end plan. Participant over age 50 deposits maximum DC plan limit profit sharing during the plan year as well as $8,000 salary deferrals. Per calendar year his deferrals are below the calendar year catch-up limit each year, however during the plan year they are as stated above. Because he exceeded the 415 limit instead of the 402(g) limit, must I limit his catch-up to $6,000 for the plan year? Or may I assign the "catch-up" contributions to the year they were deferred (thus, allowing all of his contributions for the plan year)? Most threads I have seen regarding fiscal year catch-up are tied to 402(g) limits and ADP corrections.

[Advert.]

The DOL is coming ... Pension plan audits are on the rise with a specific focus on the Term-Vested population and RMD. Contact the pros at PBI to learn more about our new Term-Vested Audit & Remediation Service.

Employer maintains a profit sharing plan, no employees. Box 1 of his W-2 includes health insurance premiums; boxes 3 & 5 do not. Employer wants max deduction (and who doesn't?). Would his 25% be based on Box 1 or Box 3? Accountant seems to think Box 3.

Can a non-ERISA steeple church 403b plan use a definition of spouse that does not reflect the Windsor amendment to DOMA? So can a church plan define Spouse to mean a person of the opposite sex to whom the participant is married, but then state that for RMD purposes, Spouse reflects the changes to DOMA as of June 26, 2013? The document to be used is a pre-approved plan that does not define Spouse in this manner, and we would need to write this definition into the plan, which could take it out of pre-approved status (which I guess is the second issue). First issue is the legality of using this definition in a church plan.

Can a 401(k) plan have a tiered match contribution based on service? No HCEs would be eligible to participate.

Our client is an LLC taxed as a partnership. There are 4 partners (all family members). We received copies of their K-1s. All four reflected the same amount of earnings in Box 14. A = $321,347. C = $658,390. Is this normal? Do I use the same amount for everyone? Or do I divide those numbers by 4 to get the individual earnings for them? Also, would I add A and C together?

We have a 401(k) plan with an automatic enrollment provision (ACA). The client has not provided the required notice for the past two years. They've been operating according to the provisions in the plan document; they simply neglected to provide employees with the notice. Is there a "correction" for this? Maybe anyone who was auto-enrolled would need to be given the option to remove their funds?

A recent BenefitsLink discussion shows differing views about which set of provisions is likelier to meet a sponsor's interest, and perhaps about how the point might be explained in a plan design discussion (or instead presumed).

https://benefitslink.com/boards/index.php?/topic/62281-that-a-retirement-plan-required-no-spouses-consent-for-a-distribution-before-the-participants-death-meant-a-surviving-spouse-gets-no-portion-of-a-27-million-benefit/&page=2

That started me thinking about a practical point: The time available for a plan design discussion might be limited -- whether by a client's availability or attention span, a client's choice to limit a practitioner's time billed, or a practitioner's choice to limit time to sustain profitability for a fixed fee or an assumed cost. If time is limited so it's not feasible to discuss all plan design choices, how does a practitioner leading the discussion decide which topics should get little or no attention (and instead fall into some presumed norm)?