Message Boards Digest

August 11, 2020

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

austin3515 created a topic in 401(k) Plans

ADP Safe Harbor But Not ACP -- Will This Work?

"Plan currently has a dollar for dollar match on first 10%. I think I can have a dollar for dollar match on the first 4% as safe harbor, and then dollar for dollar on the next 6% as a discretionary match. I would still get to keep my ADP Safe Harbor, but obviously no ACP Safe Harbor. My understanding is that this does not create any problems at all, right? I just have to run my ACP Test."

6 replies   |    78 views   |    Add Reply

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TPApril created a topic in 401(k) Plans

SECURE Act -- Removal of Employer Safe Harbor Notice Requirement

"Per the SECURE Act, safe harbor nonelective plans no longer need to provide the annual safe harbor notice every year. So, for plan that provided notice in 2018 for 2019, no notice will be provided in 2019 for 2020. Does that make the safe harbor nonelective contribution optional because no notice was provided that it is indeed being contributed?"

1 reply   |    37 views   |    Add Reply

Scuba 401 created a topic in Distributions and Loans, Other than QDROs

Tax Consequences of Rollover Into Probably-Disqualified Retirement Plan

"This case involves a rollover to a qualified plan. We think the plan was never qualified and therefore the rollover was improper. I think the tax consequences would be that the entire rollover would be taxable and subject to the 6% excess contributions excise tax. Agree? Also, I wonder if the IRS would allow the taxpayer to back out the rollover and roll it into an IRA which would then allow him to start taking RMDs and maybe pay the 6% excise tax only for the years the contribution was in the plan."

2 replies   |    25 views   |    Add Reply

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