Message Boards Digest

April 12, 2018

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

Author's photo

AATPA created a topic in 401(k) Plans

Off-Calendar Year End Plan, Catch-Up Contributions

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.
Number of replies posted  9 replies      Number of times viewed  102 views      Add Reply

Navigating the Compliance Challenges of Missing Participants

Sponsored by Pension Benefit Information, Inc.
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.
Author's photo

thepensionmaven created a topic in Retirement Plans in General

Sub S Shareholder 'Wages'

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.
Number of replies posted  8 replies      Number of times viewed  89 views      Add Reply
Author's photo

30Rock created a topic in Church Plans

Church Plan and Definition of Spouse

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.
Number of replies posted  4 replies      Number of times viewed  48 views      Add Reply
Author's photo

Santo Gold created a topic in 401(k) Plans

Tiered Matching Contributions Based on Service?

Can a 401(k) plan have a tiered match contribution based on service? No HCEs would be eligible to participate.
Number of replies posted  3 replies      Number of times viewed  42 views      Add Reply
Author's photo

coleboy created a topic in 401(k) Plans

Partners and K-1 Earnings

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?
Number of replies posted  2 replies      Number of times viewed  38 views      Add Reply
Author's photo

Tinman created a topic in 401(k) Plans

Automatic Enrollment -- Notice Not Provided

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?
Number of replies posted  0 replies      Number of times viewed  17 views      Add Reply
Author's photo

Fiduciary Guidance Counsel created a topic in Retirement Plans in General

How Do You Decide Which Topics to Omit from a Plan Design Discussion?

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).

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)?

Number of replies posted  5 replies      Number of times viewed  55 views      Add Reply, Inc.
1298 Minnesota Avenue, Suite H
Winter Park, Florida 32789
(407) 644-4146

Lois Baker, J.D., President
David Rhett Baker, J.D., Editor and Publisher
Holly Horton, Business Manager

Copyright 2018, Inc. All materials contained in this mailing are protected by United States copyright law and may not be reproduced, distributed, transmitted, displayed, published or broadcast without the prior written permission of, Inc., or in the case of third party materials, the owner of those materials. You may not alter or remove any trademark, copyright or other notices from copies of the content.

Links to web sites other than and are offered as a service to our readers; we were not involved in their production and are not responsible for their content.

Unsubscribe | Privacy Policy