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Message Boards Digest

November 15, 2019

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

hileman created a topic in 401(k) Plans

Effct of Catch-Up Contributions on ADP Test of Fiscal Year Plan

"Plan year is 7/1/19 - 6/30/20. HCE defers on pay date 12/15/2019 -- $25,000. Nothing else deferred in the 2019 calendar year. HCE defers on pay date 1/15/2020 -- $26,000. Nothing else deferred in the 2020 calendar year. Is my ADP test for the plan year ending 6/30/2020 going to show deferrals of $51,000? Or will it show $38,500 deferrals because 2019 is less a $6,000 catch-up and 2020 is less a $6,500 catch-up?"

Number of replies posted  1 reply      Number of times viewed  43 views      Add Reply

BG5150 created a topic in Retirement Plans in General

Plans Moving to a MEP -- Questions on Compliance Testing and Contributions

"When do you complete your compliance testing for plans moving to a MEP? It's unlike a regular plan termination, when we still have the assets and can do all the testing and required corrections and contributions before the assets get liquidated. How do you handle that for a plan leaving for a MEP? Just do the annual work and do the corrections/contributions to the new plan? Hold off on the transfer until it's all done?"

Number of replies posted  0 replies      Number of times viewed  26 views      Add Reply

jireh87 created a topic in Health Plans (Including ACA, COBRA, HIPAA)

Successful ESRP Avoidance

"Has anyone been successful in avoiding the proposed ESRP for clients who did not offer coverage? I know reasonable cause is not an acceptable reason for not offering coverage, but I was wondering if anyone has been successful in either avoiding or reducing a proposed ESRP pursuant to a 226-J letter."

Number of replies posted  1 reply      Number of times viewed  28 views      Add Reply

Dougsbpc created a topic in 401(k) Plans

Solo 401(k) Plan OK Despite 414(m) Aggregation with HCE-Only Company?

"Can a business owner maintain a solo 401(k) plan if the business would be considered an affiliated service group with another company? The other company only has greater than 5% owners. What if the other company had employees with no ownership who would be eligible for the solo 401(k) plan?"

Number of replies posted  3 replies      Number of times viewed  48 views      Add Reply

tghooper created a topic in 401(k) Plans

Tax Deductible Contribution After Plan Termination?

"A plan terminated 12/31/2018. Employer failed to make required contributions in prior years and made them in 2019. Let's assume that they never deducted these on a prior year's tax return and we're self-correcting under EPCRS. Because there is no eligible compensation under 404, is this subject to excise tax on Form 5330? Or are these non-deductible contributions?"

Number of replies posted  3 replies      Number of times viewed  69 views      Add Reply
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