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December 20, 2021

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

maryflemingphr@yahoo.com created a topic in Defined Benefit Plans, Including Cash Balance

Cash Balance Contributions Appear on Form W-2?

"Do cash balance contributions get reported on the W-2? If so, which box?"

1 reply so far   |    Click Here to Add a Reply
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Tax Cowboy created a topic in Retirement Plans in General

Audit Requirement for a New 200+ Participant ESOP

"Group: Plan sponsor adopted an ESOP in November 2021. I'm told they have 200 participants. I note they fall into a large plan. Because the adoption date falls late in the year (for the first short year), is the plan exempt from the usual independent audit requirement until plan year that ends December 31, 2022? Also, when is an audit merely a 'limited scope' audit? Is that determined by the IQPA? The plan sponsor?"

2 replies so far   |    Click Here to Add a Reply

Catch22PGM created a topic in 457 Plans

Plan's Definition of Compensation Is 'Base Salary' But Deferrals Taken from a 'COVID-19 Bonus'

"A non-governmental 457(b) Adoption Agreement defines compensation as 'Base Salary'. A participant elected to have 5% of pay deducted and contributed to the plan in 2021. The plan sponsor paid a 'COVID-19 Bonus' in 2021, withheld 5% from that bonus, and contributed it to the 457(b) Plan. The participant is fine with the 5% withholding, so would a plan amendment to the definition of compensation to include bonuses suffice? Neither the plan sponsor nor the participant is interested in finding a way to remove the funds from the account that has been established. We're only talking about a $100 contribution so nobody wants to spend too much time on it, but I want them to do whatever is needed and to do it properly."

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Bird created a topic in Retirement Plans in General

Sister Is Deemed to Own Her Mother's Interest in a Trust?

"Son owns 1/3 of company stock. Other 2/3 is owned by a trust, of which son's mother is an income beneficiary. Sister owns no stock directly. I'm noodling over whether the mother's trust interest is attributed to sister. Initially I thought 'of course,' but then read somewhere that only an actual ownership interest can be attributed. Then I looked in 'Who's the Employer' and now I'm confused even more. I suppose we need to see the trust instrument to know exactly how and when mother would be able to get more than just income, but let's assume she has only an income interest. Or is that even important (does the rule against double attribution mean the nature of the mother's interest doesn't matter)?"

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cheersmate created a topic in Cross-Tested Plans

Bifurcated Testing for Cross Tested Safe Harbor 401k

"5 participant plan - 3 HCEs (1 older, 2 young) and 2 NHCEs (1 older, 1 young). Plan provides 401k, 3% SHNEC and discretionary PS by rate group (each participant is in own). The Gateway is 5% (satisfied by 3% SHNEC + 2% Profit Sharing).

I would like to restructure for (a)(4) testing:

1 HCE (older) and 1 NHCE (younger) based on cross-testing; and 2 HCEs (younger) and 1 NHCE (older) based on allocation rate testing.

Is the coverage for Cross-Testing component coverage:

(1NHCE/2NHCEs) / (1HCE/3NHCEs) = 150%?

and the Allocation Rate component coverage:

(1NHCE/2NHCEs) / (2HCE/3NHCEs) = 75%?

The NHCEs EBAR is at least as great as the older HCEs. The Allocation Rate is the same 5% for the 2 young HCEs and 1 older NHCE -- 3% Safe Harbor Non-Elective plus 2% Profit Sharing

The plan passes, correct?"

7 replies so far   |    Click Here to Add a Reply

TPApril created a topic in 403(b) Plans, Accounts or Annuities

402(g) Limit Applies to State Employee Who Also Works in Private Sector?

"State employee participates in a state-sponsored retirement plan. He also works for his wife's firm, which has a 401(k) plan. I know 415 limits are plan-specific, but is there an individual 402(g) limit that combines contributions to the state-run plan as well as the private plan?"

3 replies so far   |    Click Here to Add a Reply

Indu created a topic in Humor, Inspiration, Miscellaneous

H4-EAD for 401(k) Plan Administration Jobs

"I would like to clear few of my ambiguity regarding 401k administration jobs. Before starting I brief about my work experience: I have worked as outsourced associate for few of the leading TPAs for 6.5 years. Having hands-on expertise on compliance testing, valuation, trust accounting, Form 5500s etc. knowledge on distribution & loan. softwares handled: Relius, ASC, ftwilliam.com, Quicken, pension pro etc., completed RPF courses in 2016. My questions: [1] I am on H4-EAD (work authorization for dependents of H1B visa holder). Will I be hired by TPAs in US? Will my visa be the problem for getting job as a 401k associate? [2] I have 4 years break in service. Since I worked for 6.5 years in same area I am still very much familiar with 401k. Does my break in service affect my job search? [3] If I pursue QKA courses, would it help me for my job search? [4] If at all I find a job as 401k associate or administrator, what would be the average salary that I can negotiate for?"

1 reply so far   |    Click Here to Add a Reply

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

PBGC's 'MyPAA' Site Is Offline Until Dec. 22

"The PBGC has shut down its site until 9 p.m. on December 22. How can this be, given that filings must be done prior to January 3, 2022?"

1 reply so far   |    Click Here to Add a Reply

SSRRS created a topic in Form 5500

Should LLC File a Form 5500-EZ? Or a Form 5500-SF?

"An LLC has a DB plan. The only particiapnts are the two owners of the LLC. The LLC is taxed as a corporation (not as a partnership). Should the plan file a 5500-EZ? Or a 5500-SF?"

1 reply so far   |    Click Here to Add a Reply

Plan Doc created a topic in 401(k) Plans

Can Asset Seller Distribute from Its Terminated Plan Despite New Status as Member of Affiliated Service Group?

"Seller of assets terminated its 401(k) plan the day before the asset sale to Buyer. In connection with the transaction, some Seller employees became employed by Buyer. Others remained employed by Seller. The transaction created an affiliated service group comprising Buyer and Seller. Employees of Seller hired by Buyer and employees remaining with Seller will participate in Buyer's 401(k) plan, with Seller becoming an adopting employer of Buyer's plan. If Seller were to distribute the accounts from its terminated plan, would the successor plan rule be violated?"

1 reply so far   |    Click Here to Add a Reply

ratherbereading created a topic in 401(k) Plans

Safe Harbor Match on Bonus?

"Plan uses a basic safe harbor matching contribution formula. Participant received a $1,000 bonus and elected to defer 100% of said bonus. Does he get the Safe Harbor match?"

5 replies so far   |    Click Here to Add a Reply

Tom Poje created a topic in Humor, Inspiration, Miscellaneous

Answers to the Christmas Puzzle

"Humbug. The Grinch and Mr. Scrooge are not happy about posting this. Merry Christmas to all christmas puzzle - 130 protected with answers.xls"

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Lou81 created a topic in Defined Benefit Plans, Including Cash Balance

Moving Money from Cash Balance Plan into a Roth IRA

"I have a cash balance plan that is terminating. A participant wants to roll his cash balance money into a Roth IRA. Do I withhold the 20% and report it as taxable on the 1099-R? How would I code the 1099-R?"

2 replies so far   |    Click Here to Add a Reply

Belgarath created a topic in 403(b) Plans, Accounts or Annuities

Form 5500 Required If Otherwise Exempt Employer Adopts an ERISA 403(b) Plan Document?

"Non-profit organization's plan qualifies for non-ERISA status, but utilized an ERISA 403(b) document (apparently unintentionally). Has never filed a Form 5500. Obviously can use DFVCP program, so costs are not onerous. I see no option. By executing an ERISA document, it seems to me that they have elected ERISA status, and they can't say it is 'non-ERISA' just because they would otherwise qualify for non-ERISA status. Agree?"

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

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Retirement Plan Administrator - 401(k)/DC Specialist  View details

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AZ / CA / CO / NV / OR / UT / WA

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PACETPA
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View job as Defined Benefit Administrator

Defined Benefit Administrator  View details

PACETPA
Remote / Clovis CA / NV

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