The employer occasionally uses the services of a temporary agency to find new talent. Occasionally after 90 days the "temp" is offered a permanent position with the employer. Does the employer have to count service while a "temp" for the plan's eligibility waiting period, vesting credits and accruals? In other words, does the employer have to bridge that service while working "temp" now that they are hired to a permanent position with the employer?

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One of our clients had an accidental death. Her business was real estate. Her husband can receive her post-death commissions for a time. Can a contribution be made for her, for the 2018 plan year?

A safe harbor 401(k) Plan will be terminating 12/31/2018. Two participants are over age 70-1/2 but are not 5% owners and have not separated from service. Are they required to receive a 2019 RMD from the plan if they are employed when the distribution is made in 2019? If they aren't required to take an RMD and they roll over 100% of their balance due to plan termination but later separate from service before 12/31/2019, is a retroactive RMD triggered for 2019?

Which governmental activities stop (or continue) during a U.S. government shutdown? Here's the DOL plan, the IRS plan, and the contingency plans of other agencies.

In our FIS Corbel document under Maximum Annual Additions, it provides in part that if an employer contribution otherwise would cause annual additions to exceed maximum permissible amounts, the contribution is reduced and any amount in excess of the maximum permissible amount that would have been allocated "may be allocated to other Participants." Our employer-customer's plan has only three participants, who are owners or related to owners (no other employees, all HCEs). Two out of three of the participants have maximized their 401(k) for the year. When we determine the 25% deductible employer contribution based on eligible compensation and we allocate based on plan formula, these two participants will hit their 415 limit. Which then, per the plan document, would be allocated to the other owner who did not defer. Any problems with allocating additional monies to this third participant once the first two participants have reached their 415 limit? I have been told this is aggressive but I can't find any guidance that says we cannot do this.

Can a 401(k) plan allow for Roth rollover contributions but not Roth elective deferrals? If not, why not?