Message Boards Digest

January 29, 2019

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

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coleboy created a topic in 401(k) Plans

Safe Harbor Change: QACA to Traditional

We are in the process of taking over a plan that is currently a QACA Safe Harbor plan. Client would like to switch to a traditional safe harbor. Can this be done?
Number of replies posted  1 reply      Number of times viewed  38 views      Add Reply

ASC CE Webcast: New Hardship Distribution Rules for 401(k) Plans

Sponsored by ASC
Review the new IRS recently proposed regulations which have a major impact on 401(k) plan compliance and operation. Topics include new hardship distribution events, elimination of the 6-month suspension and loan requirements, and more. Register Now!
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Nancy D created a topic in 401(k) Plans

Handling Excess 415 for Terminated Employee

A 401k plan participant terminated employment in early 2018 and received a taxable distribution in 2018. His pre-tax deferral, Roth contribution and match exceeded his compensation for the year, resulting in 415 issue. In looking at EPCRS, per our volume submitter document in an 415 excess situation, it seems the correction is to distribute the funds plus earnings to him. We did this. The employer wants to self-correct because the total excess is under $100. Is there anything we need to do other than document their decision?
Number of replies posted  3 replies      Number of times viewed  32 views      Add Reply
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BG5150 created a topic in 401(k) Plans

402(g) excess included in 415?

We have someone who deferred 26,000 in 2018. Obvious 402(g) excess. But do I include the $1500 excess amount in 415? In other words, what is the maximum PS: $35,000 (incl excess in 415) or $36,500 (do not include it if it is distributed)? I believe it is counted, but I cannot look it up in the EOB at the moment.
Number of replies posted  2 replies      Number of times viewed  29 views      Add Reply
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pmacduff created a topic in Distributions and Loans, Other than QDROs

RMD for active owner rolled balance

Pooled funds balance forward Profit sharing plan has an active owner who took his RMD for 2018 and then rolled the rest of his balance to his IRA account. He still takes a small salary so there will be a new balance in 2019 due to the 2018 profit share allocation/deposit done in 2019 (some time between now and 03/15). I believe that RMDs can be computed on a cash basis and his balance as of 12/31/2018 was $0.00, so in theory the 2019 RMD would be $0.00. He will have a balance as of 12/31/2019, however, so RMD would again be required for 2020 anyway. OR - because the plan is reported on an accrued basis including the 2018 profit share allocation is the RMD required for 2019 as he has an accrued balance as of 12/31/2018? I assume if he rolls his 2019 balance once the ps deposit is made, then the RMD would have to come out prior to the rollover?
Number of replies posted  4 replies      Number of times viewed  26 views      Add Reply, Inc.
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