If a rollover comes from a SIMPLE IRA to a 401(k) of the same employer, does that count as a related rollover?

[Advert.]

Prepare for and add value to meetings with prospective and current clients with our Plan Data Intelligence/Operational Benchmarking tool. Customize with your logo/color themes. Contact us 612-605-2266, sales@ERISApedia.com

New plan to be effective 1/1/2018. Participant count will apparently be 101, so audit would be required. What if the 2 owners are excluded? Are excluded employees who have otherwise satisfied eligibility considered "participants" for BOY count purposes? The 5500 instructions don't seem crystal clear on this. If they don't have to be included, we could exclude the owners, then amend the plan, say, February 1 to bring them in. Seems a little too cute, and the consequences of not filing with audit if required are, of course, draconian. The phrase "earning or retaining credited service" in the 5500 instructions makes me nervous... P.S. -- FWIW, it seems to me that under 2510.3-3(d)(1)(ii)(A)(2) you are still a participant, even if in an excluded class.

Participant takes loan on his vested account balance, terminates several months later, having only repaid 2 quarterly installments. I believe the total account balance is the investment fund balance plus the outstanding loan balance. Participant wants to take his money, default on the loan. Loan default would be outstanding balance as of the date of last payment plus interest through the term of the loan. He is eligible to rollover the investment portion of his account and the loan balance plus accrued interest is taxable. Two 1099Rs, one for the rollover, one for the loan default. (Participant is over [59] Sound correct?

Can anyone tell me a reason for choosing ADP Safe Harbor only in the Adoption Agreement? Why wouldn't you always choose ADP and ACP Safe Harbor?

CPA is telling me that a maximum deduction is: Schedule C: 1/2 SE minus Medical Ins. = Max Deduction; so $51,320 minus $3,626 minus $14,400 = $33,294 but I would instead think it's $33,539. I have never heard of a Medical Insurance offset limiting the contribution. Have I learned something today (and so it's time to go home)?

For the schedule of reportable transactions (schedule 4i), should the activity be listed at a fund level (if many investments within the fund) or at an investment level?

Have 3 plans that must be aggregated for testing. All use a safe harbor match. One plan has most of the HCEs. It's immediate entry for the SH MC. The other 2 plans are age 21 with 1 year of service, and dual entry, for the SH MC. The regs say for SH MC to satisfy the ADP/ACP testing, and that the "rate" cannot be greater for the HCEs than for non-HCEs. If my HCEs are getting in immediately but non-HCEs in the other plans must wait a year (and then come in on dual entry dates), am I required to run ADP? ACP? Both?

If a group offers a DCFSA plan having an off-calendar year (Feb. 1 through Jan. 31), can an employee change payroll contributions so that his entire election amount ($5,000) worth of contributions is reported on his W-2 for the calendar year, and then stop contributions for the last month of the plan year (January)? If allowed, would this impact the new plan year election amount?

A plan terminates in 2016 and funds were distributed. Company opens new plan for 2018. Are those plan distributions added back in as in-service withdrawals for 5 years?