"I'm struggling a bit with the proper use of the VCP submission forms. The 14568-B doesn't seem to quite "fit" a 403(b) plan that had a written plan document, yet failed to restate by the extended deadline this summer. https://www.irs.gov/pub/irs-pdf/f14568b.pdf Has anyone else submitted one of these yet, and if so, with any results? It appears to me that you'd have to check Section I(A) last option (other). "B" does not appear to apply, and Section II(B) doesn't appear to apply either. Looks like you'd check the Section 1(A), describe them as a nonamender, and include signed updated docs and any Amendments. Am I missing something obvious here? Thanks."

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"We have two entities owned separately by husband and wife that are under common control due to a minor child. Minor child will be 21 mid-2021. At that point, ASSUMING no other attribution rules apply for the spouses (no ownership in the other entity by either or management/oversight, not in a common law state, etc.), can a plan be opened after the child's 21st birthday with an effective date of 1/1/2021? Must it have a short plan year or fiscal year beginning after the birthday since the entities were under in a controlled group at some point in 2021?"

"A small firm wants to start a 401-k plan with salary deferrals but all are 1099 employees. Are they able to do salary deferrals? Would they have to "take" a salary to make a deferral? Thanks"

"Assuming the DB allows it, Can a 401(k) or PS account be rolled over to a regular DB or a 412(e)(3) and the funds remain segregated? I'm particularly concerned with the rollover to a 412(e)(3)."