"I am trying to determine when the first RMD is due for this participant in a Cash Balance Plan. He is 100% owner of the plan sponsor. Turns 70-1/2 in 2018. Plan's original effective date is 1/1/2018. Plan uses an end of year (12/31) valuation date. Plan excludes service prior to the effective date for vesting purposes. Vesting schedule is 3-year cliff. Would the first RMD be due 4/1/2021?"

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"Does anybody know of or have a template for a Permanent Opt-Out Form?"

"Employer uses a uniform formula for allocating profit sharing contributions. The formula utilizes various classes of employees based on years of service. The employer wants to further pro-rate each employee's share by the number of weeks in the year that the employee is actively employed. Is this allowed under 1.401(a)(4)-2(b)(2)? If not, is there another basis for allowing the pro-ration?"

"Taxable third party sick/disability pay (e.g., where the premiums are employer paid or are treated as such because they are made pre-tax through a cafeteria plan) would be included in a W-2 definition of plan compensation. As a practical matter, how are deferrals on these amounts handled where the amounts are paid by the third party insurer directly to the participant? Do any insurers actually withhold deferrals and forward to plan sponsors for deposit in the plan?"

"There is a SH plan and a Non-SH plan in a control group. They both pass coverage on their own, so aggregation for ADP/ACP is not required. However, there is at least 1 key employee in each plan, so they must be aggregated for Top Heavy purposes. The plans are top heavy. Do the Non-Key employees in the SH plan have to receive the Top Heavy minimum contribution? Because that plan is SH, my thinking is that they don't."