"A company was sold through an asset sale. The retirement plan was not addressed in the agreement. All employees started with the new owner on 12/1. We received a rollover check for a participant with a balance in the old employer's plan. The new owner has not set up a plan and I do not see anything being set-up for 90 days. Do you think I am OK to process the rollover check into the old plan? The rollover was initiated prior to 12/1, however, technically the old plan now has no active employees, so I am questioning if a former employee can make a rollover into the plan. It's a unique situation for the participant, who was not aware the company was in the process of selling. I would like to process the rollover, but what I like and what is correct may be different in this circumstance."

"Good luck. Simply print out the song list on the second page and enter the number of the song in the corresponding yellow box. It will tell you whether you made a good guess or not. Scrooge told me to wish you a Bah Humbug as well. christmas_puzzles__130_to_solve.xls"

"It's time. 500 clients-- 280 being DB/CB plans, mostly small. Clients across the country but mostly NJ. EA would come to shepherd cases as necessary plus maybe one administrator."

"Is the Special Tax Notice required to be provided to a participant requesting an in service distribution?"

"An insurance agency says that its employees are statutory employees, but pays them W-2 income instead of 1099 income. Their W-2s consist entirely of commissions and they all work from home. They work as they wish -- essentially as independent contractors -- but are paid a W-2 income. Is the agency able to exclude them from their 401(k) plan? It seems that most statutory employees who get paid 1099 income may not be considered eligible employees, but I couldn't find information that discusses how eligibility is handled when their income is reported on a W-2. Has anyone come across a situation like this?"

"Person terminated in 2021 and his required distribution date is 4/1/2022. The form of benefit taken is a lump sum. The amounts not eligible for a rollover should be calculated for 2 years, 2021 and 2022. Generally to calculate the amount of RMD that is not eligible for rollover under the account method, you would divide the lump sum amount by the distribution period taken from the Uniform Life Table. The two distribution periods will correspond to the age of a participant as of 12/31/2021 and as of 12/31/2022. Effective 1/1/2022 the IRS amended the Uniform Life Table with longer distribution periods, and therefore smaller RMD amounts.

So question is: Will you use both distribution periods from the amended table, or will you use the distribution period from the old table when calculating RMD amount associated with 2021, and the distribution period from the new table when calculating RMD amount associated with 2022?"