Message Boards Digest

September 27, 2021

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

chibenefits created a topic in Form 5500

Change in Plan Sponsorship from One Controlled Group Member to Another

"Controlled group situation. The entity within the controlled group that sponsors the retirement plan is being sold. Client wants to 'transfer' the sponsorship of the plan to one of the remaining entities within the group. How would we handle the change in the EIN of the sponsor of the plan when filing the 5500?"

2 replies so far   |    Click Here to Add a Reply

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

IRS Assessing a $150,000 Penalty, Not $15,000

"DB Plan, owner only, and EZ Filer. Recived an IRS CP283 Notice for late filing of a Form 5500 -- for PYE 12/31/2017, a penalty of $150k. He has filed all timely. Even more perplexing is that the notice states clearly that for plans up to 12/31/19 the max. penalty is $15,000 and for forms due after 12/2019 the max penalty is $150,000. Because this notice is for the 2017 (due prior to 12/2019) year, why are they charging above the $15,000 maximum penalty? I did hear that Ogden UT (where they recive the 5500-EZ filings) was still closed at October 15, 2020. Are they processing the 2019 forms now and saying they're late? On the other hand the notice says this is for the 12/31/2017 year-end."

4 replies so far   |    Click Here to Add a Reply

HCE created a topic in 409A Issues

New Trustee Wants Rabbi Trust to Get an EIN -- Jeopardizes Unfunded Status?

"We recently moved from one trustee to another. The old trustee did not require us to get a separate EIN for the rabbi trust. The new trustee does, saying a separate EIN is needed to file a Form 1041. Is this a concern? Could a separate EIN jeopardize the unfunded status of the nonqualified plan/rabbi trust? Is there any risk of not having a separate EIN? Can we (is it reasonable to) push back here?"

No replies yet   |    Click Here to Add a Reply

JF created a topic in Health Savings Accounts (HSAs)

Correcting Delinquent Employer Contributions to HSA After Tax Return Due Date Has Passed

"IRS Notice 2008-59 (Q&A 21) states that employers can make HSA contributions for a prior tax year, if the contribution is made by the federal tax return due date (without extensions). What can an employer do to correct delinquent contributions if the tax return due date has already passed for the previous year?"

1 reply so far   |    Click Here to Add a Reply

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

Is This a Funding Assumption Change for Schedule SB Purposes?

"I'm looking at an SB prepared by another actuary for a terminated plan. It was a calendar plan with val date as of end of year. SB was prepared with 9/30 year end (term date) which is fine. When SB was filed, this val date change was filed as a funding assumption change. Is that correct?"

4 replies so far   |    Click Here to Add a Reply

VeryOldMan created a topic in 401(k) Plans

Calculating 415 Limit for SP with QRP allocations + 401k

"I have a SOLE PROPRIETOR issue regarding 415 and shutting down the QRP Plan. There are no employees. The SP has Earned Income of $100,000 for 2021. He has a QRP profit sharing plan consisting of an asset transfer from an overfunded DB that was terminated in the prior year. There is also a separate 401(k) plan and owner wants to make a $15,000 401k deferral plus allocate the remaining assets in the QRP and terminate that Plan this year. The QRP has $43,000 in unallocated assets in the transferred assets suspense account. The Earned Income is $100,000 and there are several issues:

[1] Can the $43,000 be allocated to the SP this year? The plan doc for the QRP (FIS) states only the minimum amount to allocate under the 7 year rule.

[2] If the $43,000 can be allocated in the current year, how do you determine the 415 limitation? If it was a formula based percentage allocation like 20% of pay, it is easy to compute the portion that is the taxable compensation, portion eg (1-.25/1.25) and thus compute the 415 limit. I don't see how to split the $100,000 with the QRP allocation to compute the 415 limit."

4 replies so far   |    Click Here to Add a Reply

FSP created a topic in Operating a TPA or Consulting Firm

Looking to Buy DB Plan Servicing from Actuary

"Our situation is a little unique. Our DB plan business is growing and we're looking for another actuary who can provide SBs, etc. We've done a good job on the servicing side, so we would like to take over the plan servicing while still having the actuary do the back end work. The actuary would also receive add'l work thanks to our DB plan growth. Is this type of transaction realistic? It's a great chance for an actuary looking to get out of the client servicing side and just focus on the actuary work."

No replies yet   |    Click Here to Add a Reply

401kallday created a topic in 401(k) Plans

Form 5500 Reporting of Overfunded Contributions

"If an employer overfunded their employer contributions throughout the year, would you report them as contributions on the Form 5500 even though they're being moved to an unallocated account?"

1 reply so far   |    Click Here to Add a Reply

Here are the most recently posted jobs on, a service of BenefitsLink:

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Creative Retirement Systems
Remote / Cincinnati OH

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Distribution Specialist  View details

Carpenter Morse Group
Remote / Longwood FL

View job as Sr Recordkeeping Specialist

Sr Recordkeeping Specialist  View details

BlueStar Retirement Services, Inc

View job as BOLI (Bank Owned Life Insurance) Analyst (Entry Level)

BOLI (Bank Owned Life Insurance) Analyst (Entry Level)  View details

Greensboro NC

View job as 401(k) Support Staff

401(k) Support Staff  View details

Retirement, LLC
Remote / Oklahoma City OK

View job as Retirement Plan Administrator

Retirement Plan Administrator  View details

The Nolan Company
Remote / Overland Park KS

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