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Message Boards Digest

February 11, 2020

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

M Norton created a topic in SEP, SARSEP and SIMPLE Plans

SIMPLE IRA Excess Employer Contribution

"SIMPLE IRA plan has excess employer match contributed for 2 participants for 2019 plan year. The excess match totals $120, but excess is less than $100 for each participant. Rev. Proc. 2019-19 says if the excess amount is $100 or less, the Plan Sponsor is not required to distribute the excess.. The question is whether that $100 limit applies by participant, or does it apply to the plan as a whole?"

Number of replies posted  0 replies      Number of times viewed  25 views      Add Reply
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Pammie57 created a topic in 401(k) Plans

Withholding on Corrective Distribution on Account of Failed ADP/ACP Test

"Is such a distribution subject to any withholding? I assume no, because it can't be rolled over."

Number of replies posted  1 reply      Number of times viewed  41 views      Add Reply

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

Combined Plan Deduction Limit

"Client makes profit sharing deposits during the year and also has a Cash Balance Plan. In 2019, the profit sharing contribution deposited into the plan was greater than was deductible for combined plan purposes (e.g., profit sharing exceeded 6% due to it being a service company). Because the owner's portion is not deductible and is below the 415 limit, can the money stay in his account and be treated as after tax basis for taxation purposes?"

Number of replies posted  3 replies      Number of times viewed  63 views      Add Reply

Chris123 created a topic in 401(k) Plans

Employees Who Have Worked in Their Foreign Offices -- Count Their Service for Eligibility and Vesting Purposes When They Come to the U.S.?

"Corporation A maintains a 401(k) Plan in the US. Corporation A is a U.S. company with foreign subsidiaries. Corporation A has a number of employees that come and work in the U.S. from their Canada and Paris offices. Can employees who have worked in the foreign offices have their time counted towards eligibility and vesting when they come over to the U.S.?"

Number of replies posted  3 replies      Number of times viewed  54 views      Add Reply

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

401(a)(26) for Closed Plan

"Currently active DB plan with about 25 active participants. Employer will be hiring about 100 new employees later in 2020 and then more in the near future. Employer would like for those employees not to participate in DB plan. He will start a 403b plan in near future. There is one HCE in DB plan. If DB plan is frozen to new entrants effective say, 4/1/2020 and new 403b plan is established, will 401(a)(26) still apply to DB plan. And if so, if DB plan is also amended to freeze and exclude HCEs, will 401(a)(26) still apply, or will plan satisfy 401(a)(26)?"

Number of replies posted  4 replies      Number of times viewed  38 views      Add Reply
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