Message Boards Digest

June 25, 2021

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

austin3515 created a topic in 401(k) Plans

Reporting of After-Tax Contributions

"Payroll company, which by definition is in the business of processing payroll, asked my client to confirm tax reporting for after-tax contibutions. To which I responded, 'can you please have your payroll confirm who the HCEs are for 2021'? (Kidding, of course.) My understanding is that as far as tax reporting goes on W-2s and 941s, these deductions are no different than 401k loan payment. Am I correct?

I think it's one of those things where I can't find any articles on how to report it on W-2s and 941s because there's simply no requirement to do so. I'm trying to prove a negative, is the other way to look at it.

I did find this in the W-2 instructions:

'Reported in box 14, but not in box 12. -- After-tax contributions that are not designated Roth contributions, such as voluntary contributions to a pension plan that are deducted from an employee's pay.'

And Box 14 is apparently just a 'whatever you want it to be' box, nothing regulatory about it."

No replies yet   |    Click Here to Add a Reply

Dave Baker created a topic in Using the Message Boards (a.k.a. Forums)

RFC: Requiring Use of Email Address for Log-In, Not a 'Display Name'

"Hello! Here's a request for your comments on this idea: It's somewhat less secure to have the standard username/password log-in system if a would-be intruder already has a username to work with. The log-in form can be submitted multiple times with a series of commonly-used passwords, looking to see whether 01234567890 matches, for example. Currently these message boards enable you to log in using either (i) your 'Display Name' (which is displayed, natch, next to every post you've made), or (ii) your email address (i.e., the one you used when you first signed up). So somebody else would be able to enter your Display Name into a log-in form and then start throwing potential passwords into the form, until the intruder succeeds or goes to bed.

Of course, the world doesn't end if there were to be a 'break-in' -- the intruder might simply alter your posts to say 'I think ERISA attorneys are weenies' or some other heresy -- and yet many of us use the same password for our bank accounts, our Tinder accounts -- haw -- etc., so having a password that works on BenefitsLink lets them go monkeying around on other more potentially profitable websites on which you might be a registered user.

So (at long last, getting to the point here), the proposal would be to require the use of email addresses for log-in, and no longer permit Display Names for log-in. Your email address, unlike your Display Name, is not displayed on the message boards, so it's not public knowledge insofar as a message boards visitor is concerned. But of course you know your own email address, so the log-in process wouldn't be seem to be any more burdensome.

What do you think?"

9 replies so far   |    Click Here to Add a Reply

Jakyasar created a topic in Retirement Plans in General

Is This a Reasonable Class to Put in a Document as a Category Exclusion?

"A young employee is a full-time employee for several years, under a 'student visa.' Is it reasonable to exclude 'anyone who is on a student visa.' He's a non-resident alien, which is a standard exclusion in my documents. Unfortunately, he must be included in all tests due to full-time status with US-based income, at least they way I think so."

3 replies so far   |    Click Here to Add a Reply

SSRRS created a topic in 401(k) Plans

We Gave IRS Copy of the PPA Plan Document and Now They Want the EGTRRA Document

"Wondering whether this a usual and standard request -- we gave IRS a copy of the PPA document and they've come back and asked for an EGTRRA document."

1 reply so far   |    Click Here to Add a Reply

austin3515 created a topic in Form 5500

5500 Reporting for Synthetic GICs

"I'm reading that there is not a lot of clarity on this topic regarding how to report these contracts on SChedule A, D and H. Anyone have some insight.

I found this letter where someone who sounds like they know what they are talking about wrote the DOL to ask for guidance:

My conclusion: The insurance component is separate from the underlying investments in the CCT. The insurance would go on A and H as an unallocated/general accounts contract and the CCT would go on the D. How it is reported on the H depends on whether it's a DFE (I'll bet it is). If a DFE you get to just report it as a CCT on the 5500. If not a DFE technically you have to report each asset class separately (stocks, bonds, mutual funds).

Do I have it right? Does anyone have something more substantial written up?"

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PS created a topic in Plan Terminations

Account for Deceased Participant Having Estate as Beneficiary, But Estate Administrator Is Unresponsive

"One of my clients' plans is terminating. It has one deceased partipant (estate) account. The participant died in 2020. Because there was no beneficiary, the decedent's estate became the beneficiary. An estate beneficiary account was set up. Because the plan is terminating, the client has informed the Estate Administrator to move the funds out of the 401k plan. The Estate Administrator remains unresponsive.

Given that the client has done its due diligence, and because the Estate Administrator remains unresponsive, can the funds be rolled over to an IRA account? Can a deceased estate (beneficiary) account be rolled over to an IRA?

The deceased was from the state of Indiana. Is there anything particular that needs to be considered looked into, under Indiana law?"

No replies yet   |    Click Here to Add a Reply

John Ingle created a topic in Defined Benefit Plans, Including Cash Balance

Impact of COVID-19 on IRS 417(e) Mortality Table for 2022

"Anyone have insight as to whether the 2022 IRS 417(e) Mortality Table (used, among other things, for determining minimum lump sum amounts) will be impacted by the significant decline in life expectancies during 2020 due to COVID-19? Or is there some longer lag time between when this hit to life expectancies will start to appear in these IRS mortality tables?"

4 replies so far   |    Click Here to Add a Reply

Slem created a topic in 401(k) Plans

Retirement Plan Issues Arising Due to Acquisition of Plan Sponsor's Stock

"Company A is acquiring Company B via stock acquisition. Both companies currently sponsor retirement plans. Company A has a standalone plan and Company B is part of a PEO. Once the acquisition happens, Company B will retain their own EIN and act as a subsidiary of Company A. The intent is for Company B to terminate participation in the PEO plan prior to acquisition. Post-acquisition, Company B will become a participating employer on the Company A plan. Does Company B employees have a distributable event or would participation in Company A plan be viewed as a successor plan?"

No replies yet   |    Click Here to Add a Reply

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