Message Boards Digest

February 15, 2021

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

BG5150 created a topic in 401(k) Plans

Refund After Roth Conversion

"ADP/ACP tested plan. Plan allows for in-plan Roth rollovers. HCEt does the Rollover early January of entire account. In February, plan fails ADP & ACP tests. How does the refund get processed? How are earnings taxed? Are they? All the funds are now in the Roth Rollover account."

0 replies   |    18 views   |    Add Reply

Irmat created a topic in Retirement Plans in General

Alternate Payee Allocation

"I have been contributing to OTRS since 1989. I plan to retire in 2025. I was married from 2006 to 2014. He was awarded half of the marital portion of my retirement. When you work out the percentage it comes out to 10%. Is this calculated on my final pension amount? Shouldn't it be calculated on a lesser amount since I've gotten several considerable raises since my divorce?"

1 reply   |    50 views   |    Add Reply

khn created a topic in 403(b) Plans, Accounts or Annuities

LTD Makes Employer Contributions

"We have a Long Term Disability policy where the carrier will make contributions to an employees' 403(b) account in an amount equal to what the company was contributing before they started receiving disability benefits. Does this need to be noted somewhere in the 403(b) plan document? If so, what needs to be reflected?"

0 replies   |    32 views   |    Add Reply

kdubinski created a topic in 401(k) Plans

Controlled Group - Permissive Aggregation - Plan Termination

"Company A and Company B are part of a controlled group. They each have their own 401(k) plans and TPA firms. Company A's 401(k) plan can't pass coverage on its own (neither ratio or ABT). The Plan's have been permissively aggregated for coverage and discrimination testing purposes in prior years. I anticipate having to permissively aggregate the plans for the 2020 Plan Year as well although I don't have data for Company A as of the current date. Company A will have an ownership change in April (although it could be June or July). Employees will terminate employment with Company A and become employees of Company C. Company A would like to terminate their plan prior to the ownership change. Does anyone have any suggestions in regards to the 2021 coverage test? I anticipate the plan would not be able to pass coverage on its own (for the short plan year). Would I be able to use the 410(b) transition rules? Due to the ownership change, do I get a free pass on coverage testing? Do I tell the client to wait and terminate the plan on 12/31/2021 so I can use permissive aggregation for the 2021 Plan Year? Any suggestions would be helpful."

1 reply   |    40 views   |    Add Reply

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

DB Benefit Calculation Question

"I'm an IRS EP agent but I haven't worked very many DB cases, and I had a question about my dad's situation. My dad worked for Albemarle Corp for several years. They sponsored a DB plan through Merrill Lynch. In 2017, he was filling out his benefit election form. Among several options he was given, he planned to elect 100% joint and contingent with 60 months certain. Payment was supposed to be $347.53 per month. He never completed the paperwork (he was very disorganized and lost his birth certificate and was having trouble getting it from Vietnam. He passed away in August 2021 without ever filling out the paperwork. After his death, I contacted Merrill Lynch and let them know my dad passed away, and I requested that they send a new benefit election package for my mom to fill out. We got the package, and the only option now is a lifetime pension of $218.34 per month. Does that seem right that the monthly payment would be reduced so much? I still have a lot to learn about DB plans, but I thought the payment would be much higher. I know that options are supposed to be actuarially equivalent, but it just seems way off to me."

4 replies   |    68 views   |    Add Reply

Joe created a topic in Governmental Plans

401(a) Pre-Approved Plan Providers

"I represent a federal 401(a) plan that currently has an individually designed plan. The plan is interested in moving to a pre-approved plan document structure. Does anyone know which vendors have a pre-approved 401(a) plan document that they license for use?"

1 reply   |    44 views   |    Add Reply

BG5150 created a topic in 401(k) Plans

W-2 and K1 in a Controlled Group

"Wife owns half of an S-Corp with husband. Each takes $40,000 W-2 income, defers $15,000. Also owns partnership w/husband (50-50). Both have losses of ($150,000). Each. Because there is a controlled group, can they make the 401(k) deferral b/c it came from W-2 wages? Or are they out of luck, because the combined income is negative?"

5 replies   |    68 views   |    Add Reply

BG5150 created a topic in Cross-Tested Plans

Accrued to Date Testing -- Compensation Question

"Doing a Profit Sharing. The only reasonable way the test is passing is using the accrued to date method. Contribution basis is obviously out, and the regular benefits basis is failing too. The accrued to date method is passing. But I want to make sure the compensation used is correct. Does negative income (a loss) get used as part of the average? Or do you use zero for those years? Example: Year 1: 100,000 Year 2: (50,000) Year 3: $100,000 Is my testing comp $50,000 or $66,667?"

5 replies   |    49 views   |    Add Reply

Bill Henderson created a topic in 401(k) Plans

K1 Income and Profit Share

"Trying to figure out if K1 Income can be used towards a Profit Sharing Contributions? We have a two partner 401k who pay themselves meager salaries limiting how much PS they can receive. Question is can we use K1 Income?"

2 replies   |    45 views   |    Add Reply

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