We recently discovered that a client who had a SIMPLE IRA previously sent the January 2017 contribution deposit in error to the SIMPLE plan instead of to the new 401(k) plan that was set up for 2017. However, the W-2's are correct and the funds were withheld as 401(k) deductions. Any ideas how to correct and remove contribution from SIMPLE IRA and transfer to the 401(k)? Don't think 1099-R is appropriate since tax reporting is correct on payroll side.

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I received and e-mail in late January that a client wanted to add auto escalation to their plan in time for the first paycheck in February. They were persuaded to make it effective March 1 to allow the recordkeeper time to distribute a notice. The client insisted that the increases were to coincide with each employee's hire date anniversary. The amendment to make these changes was signed in February, but the SMM has not yet been distributed. Yesterday I learned that the notice was mailed with the March 31 statements, no increases have been implemented yet, and the client only wants the increases to be effective on the first of the quarter following the employment anniversary. Because the notices were mailed late, the client doesn't believe that any correction is necessary. What is the correction for failure to provide a timely notice of an automatic escalation provision? Based on the notice going out in early April with an effective date of March 1, what is the soonest that they should implement an increase?

A potential client currently has a money purchase plan. They want to start up a new 401k plan. They plan on terminating the money purchase plan. Can the participants choose to roll over their MPP money into the new 401k plan? Or can they only roll it into an IRA?

While working on the year-end for a new safe harbor 401k, the census and salary information that we received form the payroll company reflected some employees with "On Call" and "Prevailing Wage" Earnings. Our document uses W-2 earnings as the definition of comp. Not sure what "on call" earnings are but the prevailing wage, I believe, is under the Davis Bacon Act. Should this have been addressed when setting up the plan? Do we just ignore the prevailing wage and only use their W-2 earnings?

Napa Net article today on IRS testimony on the IRS rationale behind user fee increases. Sunita Lough, Commissioner of the IRS's Tax Exempt/Government Entities (TEGE) division (who is currently assigned to lead the IRS's Tax Reform Implementation Office) provided testimony to a skeptical subcommittee to explain her rationale behind the changes.