Message Boards Digest

March 28, 2019

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

ombskid created a topic in Retirement Plans in General

IRS Website Survey -- Legit?

Client sent a fax of a request to complete an online survey at I don't like the looks of it, but I could be wrong. Has anybody seen this or completed it?
Number of replies posted  1 reply      Number of times viewed  34 views      Add Reply

draper1 created a topic in Form 5500

Plan Sponsored by Husband's Business Must File 5500EZ if Wife's Unrelated Business's Plan Has Assets > $250,000?

Wife has a solo 401k that goes over $250k. In the same year the husband starts a solo 401k for his unrelated business. Husband and wife have a minor child, so they constitute a controlled group. The 5500-EZ instructions say that all plans of the employer must file the form if the combined assets are over $250,000, so I conclude that the husband must file as well. Correct?
Number of replies posted  2 replies      Number of times viewed  38 views      Add Reply

draper1 created a topic in 401(k) Plans

How to Use SCP to Correct ADP Problem Due to Failure to Provide Deferral Opportunity for Any of the NHCEs?

The SCP program suggests for a non-safe harbor 401k plan that an acceptable correction for a missed deferral opportunity is a QNEC equal to 50% of the ADP for that group. If the only two eligible NHCEs were left out in the first year of eligibility then my conclusion is that the ADP percentage for the group is 0 and the QNEC is [0] Hence, the ADP test is failed and the HCE deferrals must be returned or recharacterized. Does this seem a reasonable interpretation?
Number of replies posted  10 replies      Number of times viewed  80 views      Add Reply

PenQ created a topic in Defined Benefit Plans, Including Cash Balance

Proper EIN Number for Form 5500 for DFE Master Trust

My company has a Master Trust that the IRS would call a Direct Filing Entity (DFE). The Master Trust has the plan assets for several individual DB plans for which we file separate Form 5500s. We file a separate Form 5500 for the Master Trust as required by the IRS. We use the plan sponsor's (my employer) EIN for each of the Form 5500 filings, but we're not sure how to report the EIN in box 2b for the Master Trust's Form 5500. The IRS assigned us a separate Master Trust number, which they would refer to as the TIN or maybe even the Trust EIN. The Form 5500 instructions aren't very clear with respect to whether the Employer Identification Number (EIN) in box 2b should be either [1] The EIN number of the Plan sponsor for all the individual Pension Plans, OR [2] the Trust ID Number that the IRS assigned for this Master Trust. Can anyone cite any authority on this, other than the Form 5500 instructions?
Number of replies posted  0 replies      Number of times viewed  16 views      Add Reply

Bumppo23 created a topic in Defined Benefit Plans, Including Cash Balance

Frozen Hybrid/Cash Balance Plans; Compliance with Interim Amendments, Particularly Vesting

Must frozen hybrid defined benefit plans comply with interim amendments by implementation/execution of said interim amendments if said interim items stood due subsequent to the freezing of the hybrid plan? Section 701(b)(2) of PPA added IRC Section 411(a)(13) which provides a special vesting requirement for hybrid plans. Hybrid plans must provide for 100 percent vesting of employer contributions after three years of service. (

Does this vesting requirement only apply to accrued benefits ensuing subsequent to the effective date of IRC Section 411(a)(13)/Section 701(b)(2) of PPA? Must all accrued benefits stand applied to this vesting schedule? One ponders the situation for other interim amendments.

Number of replies posted  2 replies      Number of times viewed  30 views      Add Reply

401(k)athryn created a topic in 401(k) Plans

Plan Terminated, Assets Distributed in 2018 -- Residual Dividends Pop Up in 2019 -- Another 5500 Required?

A plan terminates in 2018 and all assets are paid by 9/30/2018. In March 2019, residual dividends hit a few accounts and are paid out to the participants. I was planning to file a final Form 5500-SF for 2018 with an ending balance of $0 (accurate). Do I need to file the final for 2019, instead? In this case, both the beginning and ending balances will be $0 with a small amount of earnings and distributions. If I need to file the final for 2019, then I assume I should amend the filed Form 5500-SF for 2018. (I'm frustrated with the investment platform because I can't imagine why dividends posted so late, although I would guess this issue is common when plans pay out final assets in December.) I did not quote the plan sponsor a fee for a 2019 filing because 2018 was intended to be the final. I realize it's not a ton of work, but still...
Number of replies posted  2 replies      Number of times viewed  40 views      Add Reply

Dfwguy created a topic in SEP, SARSEP and SIMPLE Plans

SEP IRA with No Corporation or LLC

Can someone suggest how IRS realize our tax status? I opened SIMPLE IRA at Fidelity with no corporation and no LLC. My spouse worked as independent contractor last year. We're filing our tax return now. Can I take a benefit from SIMPLE IRA? Spouse got rollover IRA though.
Number of replies posted  0 replies      Number of times viewed  14 views      Add Reply, Inc.
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