Message Boards Digest

July 7, 2021

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

BTG created a topic in 401(k) Plans

After-Tax Contribution Deadline

"My understanding is that the deadline for a participant to elect voluntary after-tax contributions is the due date for the employer's tax return (as opposed to traditional or Roth elective deferrals, which must still be elected by December 31 (even though they can be funded later). Can anyone point me to authority either supporting or correcting that understanding? (Note: I'm specifically asking in the context of a solo 401(k) plan for a sole proprietor.) Thanks!"

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austin3515 created a topic in SEP, SARSEP and SIMPLE Plans

Schedule C Negative but 401k already funded

"I'm trying to find something that is written by the IRS or perhaps a prestigious law firm that talks about the proper treatment when a schedule C proprietor has negative self-employment income but has already funded his or her simple IRA contribution. Does anybody have such a resource? My assumption is the contributions are refunded, adjusted for gains. Because the deduction will not be taken in 2020, my assumption is that solely the investment earnings will be taxable in the year distributed. But I would still like to find something written on the topic in a formal way that I can provide to a CPA I work with."
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mmiller created a topic in Retirement Plans in General

Form 5310 - Electronic Filing

"The Form 5310 instructions indicate the Form must be submitted online starting 4/26/2021. Has anyone gone through this process? If so, did you create a Company Account under the client or the TPA? Seems a company account must be created under the client, but then the client has to complete all the info. and upload the necessary attachments which may be difficult for the client to handle. We have called the IRS and they did not have any guidance."
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5500Nerd created a topic in Form 5500

Unique PCORI Fee Question

"Some use the 5500s to determine the count for the PCORI fee. Our client had this scenario and question. I wondered if anyone could assist:

  • “Original” ERISA Plan Year : 6/1/19 - 5/31/20
  • Short ERISA Plan Year: 6/1/20 - 6/30/20
  • New ERISA Plan Year 7/1/20 -6/30/21

As this group is technically self-funded for their medical plan, they are required to pay the PCORI fee. This poses a challenge this year as they actually have two plan years which end before October 1, 2020 as highlighted above which would need to be accounted for in the upcoming PCORI fee filing. As we know, the IRS does require the PCORI fee to be paid for a short plan year. The Group typically uses the snapshot method, However, the form does not provide a spot to account for multiple plan years (e.g. the average covered lives in this case would need to be identical to “fit” within this form.). Can you offer any guidance on how the group should address this short one month plan year when paying the PCORI fee?"

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