Message Boards Digest

April 26, 2021

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

KJJ-TPA created a topic in 401(k) Plans

Application of 402(g) Catchup for Non-Calendar Plan Years

"Can 402(g) catch-up from the previous calendar year be used in the calculation of 415 annual additions maximum for the plan year?

Example for a PYE 3/31/2021:

401(k) deferral amounts for Participant X:

- 1/1/2020-3/31/2020 = $5,200

- 4/1/2020-12/31/2020 = $15,600

- Total 2020 calendar deferrals = $20,800

In PYE 3/31/2020 - $5,200 of the 2020 402(g) catchup was used to allow for a Participant X's annual additions of $62,200 ($57,000 + $5,200).

- This should mean $1,300 ($6,500 - $5,200) is still available for 402(g) catch-up, for the 2020 calendar year - The question is regarding the use of this $1,300.

Deferrals 1/1/21-3/31/21 = $6,200 - using as 415 catch up

Would the maximum annual additions for the PYE 2021 be $65,500 ($58,000 + $6,200 + $1,300)?

OR would the maximum annual additions for the PYE 2021 be $64,200 ($58,000 + $6,200)?"

2 replies   |    37 views   |    Add Reply

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

Looking for Information on Suspension of Benefits

"Can anyone provide/point me to a link that provides good and simple information on the suspension of benefit rules (or even articles)?"

1 reply   |    44 views   |    Add Reply

Tsh94 created a topic in Form 5500

Form 5500 Filing Deadlines for a Terminated Calendar Year Plan

"I am trying to figure out the 5500 deadlines for this calendar year-end plan. Plan was terminated in October 2020 but still held funds through the end of the year. Would the 12/31/2020 Form 5500 be due 7/31/2021 (or 10/15/2021 if extended) like normal?

Final payout/transfer of funds in plan was April 2021. ($0 balance left in plan as of this date). When would this final Form 5500 be due?"

1 reply   |    35 views   |    Add Reply

AlbanyConsultant created a topic in Plan Document Amendments

Timing of Amendment for Qualified Plan Loan Offsets

"This got shifted a year, but my head may not be shifting it, so I think I've got dates that don't line up. As I recall, this was originally effective sometime in 2019 in proposed regs that could be followed, and we expected that the amendment itself could be done before 12/31/20 but effective in 2019, so we drafted a whole bunch of them (that we held awaiting for a document restatement package that we still can't prepare, but that isn't part of this issue other than to say that these amendments are drafted to have an effective date of 2019 but not signed). Then there was a one-year extension, and it had a 'soft opening' in August 20, 2020, but was truly effective starting 1/1/21. So now I presume the amendment has to be done before 12/31/21 (never mind the tri-cycle restatement for the moment). Can the amendment still be effective for 2019? Or is that off the table?"

0 replies   |    5 views   |    Add Reply

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

Looking for Copy of Rev. Rul. 74-307

"Can anybody provide a hyperlink to download the text of Rev. Rul. 74-307?"

4 replies   |    39 views   |    Add Reply

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