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?

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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?

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.

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?