"I have read some of the previous discussions on how to treat an employee of a US company with a US 401(k) plan that is a resident of Puerto Rico. I think I understand that if the employee is a bona fide resident of Puerto Rico, and all service for the US company is performed in Puerto Rico, then the compensation earned is considered to be non-US source income. Correct? If so, and the plan document does not have dual provisions for US and Puerto Rico, is the employee treated as excludable for coverage, or are they non-excludable, non-benefitting?"

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"Along with the age change for the first RMD from 70-1/2 to 72, I see new tables for the calculations. It appears that the new table must be used in 2022 and going forward. So, for 2021, I can use the 'old' table? That's what my software used, but I'm looking for confirmation."

"When a plan is terminating as per IRS all participants would require to be 100% vested. Does that mean terminated as well as active participants? One plan that's terminating has participants who left employment in 2020. The client believes these participants should not be 100% vested, and that only active participants should be 100% vested."

"Have a prospect (existing plans) that may be in an ASG and may not be aware of the rules. Does anyone know of a fairly simple questionnaire that can be sent to the prospect to start the screening for this?"