"A beneficiary of an IRA has been taking distributions for many, many years. For 2019, the divisor (subtracting 1 for each year) is 1. The IRA balance at 12/31/18 was $50,000, and currently has a value of $60,000. MRD for 2019 appears to be $50,000. But what of the remaining balance? Never have seen the divisor get to 1. Any thoughts would be appreciated."

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"The plan document has a cash-out provision at age 62 for balances that are greater than $5,000: 'Involuntary cash-out of a terminated Participant's Account balance when it exceeds the cash-out amount specified in F.11a ($5,000) is deferred under Section 7.03(b) until: Later of age 62 or NRA -- payment made in lump sum only.' In this money purchase plan, some participants' balances are greater than $5,000. Because the plan is subject to the J&S rules such that spousal consent is required, is the plan prevented from cashing out participants who have a balance greater than $5,000?"

"I own a company (100%) and have my parents as employees (no ownership). My company sponsors a pension plan. Under the Code section 318 attribution rules, my parents are 5% owners, so RMDs are required. Correct?"

"When there is a reduction in fees (paid from plan assets), what is the required timing to inform participants/sponsor?"

"What happens if a plan has a termination date of 12/1/2018, but not all the assets have been distributed by 12/1/2019? It's a 401(k) plan."

"I'm double-checking my understanding of the nondiscrimination testing rules with respect to separate plans maintained by members of a controlled group. Each spouse has a separate business and sponsors a plan. Husband receives compensation from his wife's business. When performing nondiscrimination testing for the wife's plan, one uses only the compensation paid to the husband from the wife's business, correct? In other words, compensation paid by two different businesses is not aggregated even if those businesses form a controlled group."

"We have a client who owns a small business. The small business operates a SIMPLE IRA with the 5305-SIMPLE form being the governing document. She wants to move her account to our firm to manage the investments, but not force the other partners and employees to move their accounts. Obviously this would mean amending the plan to be governed by a 5304 document. Can she amend the plan to be a 5304 whenever, or would it be subject to the 11/2 (60 Day) notices? Are there any other issues I am not thinking of that could be of concern? I thought about the two year rule, but this is SIMPLE IRA to SIMPLE IRA so we are good and I think her account is older than 2 years."