Message Boards Digest

January 19, 2022

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

mjf06241972 created a topic in Retirement Plans in General

Employer Has Not Yet Funded a Safe Harbor Match for 2020

"What's the penalty for a client that has not yet (January 19, 2022) funded its safe harbor match for 2020?"

1 reply so far   |    Click Here to Add a Reply

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

Allocate a Replacement Plan's Trust Fund to Participants on Dollar-for-Dollar Basis?

"A DB plan rolled the excess assets into a qualified replacement plan. Someone mentioned allocating the excess each year dollar for dollar. For example, if an employee's salary was $58,000 then can the plan allocate $58,000 of the excess for that year?"

4 replies so far   |    Click Here to Add a Reply

katdmin created a topic in 401(k) Plans

How to Make 401(k) Deferrals When a Tipped Employee Has a $0 Paycheck?

"A restaurant client is having an issue with their tipped employees who are deferring into their plan. I've had large restaurant chain clients for who it was never a problem, so I'm trying to see whether anyone else has run into this. If tips are paid in cash, some of the employees, after taxes and deductions, have $0 paychecks. Hence there's nothing to take the deferral from. One idea is to require the employees to give the cash back to the employer in order to make the deposits. Another idea is to exclude tips, but then I'm not sure they would pass 414(s). Any guidance would be appreciated."

No replies yet   |    Click Here to Add a Reply

#toomanyrules created a topic in Cross-Tested Plans

Struggling to Determine How to Use Prevailing Wage Contributions in a Cross Tested Plan

"Plan A is a Safe Harbor Match, calendar year-end plan that provides for prevailing wage contributions and a cross-tested profit sharing contribution. Allocation conditions for profit sharing are last day and 1,000 hours. Document allows prevailing wage contributions to offset all employer contributions.

I'm (somewhat) familiar with using Prevailing Wage contributions as QNEC in the ADP test. However, as the plan is Safe Harbor, I don't need the prevailing wage to count as a QNEC for ADP testing.

I am struggling with how to approach the Prevailing Wage contributions for cross-testing. Its my understanding these contribution are treated as Non-Elective Contributions for testing purposes. Thus, logically, I should include them for gateway and 401(a) cross-testing. This is a takeover plan and based on the 2020 Valuation Reports, I can see the prior TPA included the Prevailing Wage in gateway and 401(a). Is this the general consensus in how to test these prevailing wage contributions?

If I were using the prevailing wage in ADP as a QNEC to help pass ADP testing, I think there would be some additional considerations/limitations in whether and how to use those prevailing wage contributions in cross-testing. But, since I am not doing so, is it as straight-forward as just adding them as if they were profit sharing contributions?"

1 reply so far   |    Click Here to Add a Reply

Dobber created a topic in IRAs and Roth IRAs

Calculating RMD for a Spousal Beneficiary After Participant's Death

  • Traditional IRA owner, 82, died in December 2021 - He took his 2021 RMD prior to his passing
  • Surviving spouse, 81, 100% primary beneficiary
  • Surviving spouse transferred his IRA assets to her traditional-IRA. However the transfer of assets occurred in 2022 - therefore his IRA had a 12/31/21 value

[1] Is a 2022 RMD due on the (now deceased husband's) IRA based off the 12/31/2021 account value?

[2] Does the wife include the balance in determining her 2022 RMD?

What am I missing? All guidance is welcomed"

1 reply so far   |    Click Here to Add a Reply

Lucky32 created a topic in Distributions and Loans, Other than QDROs

Use of 1099-R for Surviving Spouse Whose Plan Account Receives a Rollover But Then Makes a Rollover

"A husband and wife are participating in the same plan and they are each others' beneficiaries. The wife dies in 2021 and the husband elects to 'roll over' her $40,000 benefit within the plan, that is, her benefit will now be shown as a segregated rollover account for him in the plan. The resulting 1099 will show him as the recipient and use code 4G to show a death benefit that was rolled over.

The husband then terminates his employment and elects to roll over his $30,000 account balance and the new $40,000 rollover account into his IRA during 2021. The 1099 for that rollover will show a gross distribution of $70,000 and show code G.

The two 1099s will seem to show distributions totaling $110,000 for the husband as recipient when he only actually had $70,000 paid out. Is this the correct way to report these transactions?"

2 replies so far   |    Click Here to Add a Reply

austin3515 created a topic in 401(k) Plans

EPCRS Before a Mistake Is Made

"Let's say a client has 6 month eligibility for 401(k) but a 1-year wait for a match in the document. But let's say the client communicated to the previous TPA that they wanted the match eligibility to line up with 401(k) eligibility and had communicated that to the prior TPA when they were doing the Cycle 3 restatement.

We prepared the match based on a 1-year wait. Problem: the client has told the employees they are eligible for the match under the 6-month eligibility.

Let's say hypothetically we didn't even look at the document and just prepared the match based on the 6-month eligibility because the client told us to and they funded it. Then a CPA auditor comes and says, 'Hey what the heck you didn't use the 1 year eligibility for the match?' Our response would be, 'Good catch, I'll self-correct with an amendment today to get rid of that.'

By that rationale, if we catch it BEFORE the mistake is made (which is our case), shouldn't we have the same opportunity to self-correct via amendment, especially when we are increasing benefits to non-HCEs? It seems unfair to punish someone for NOT making a mistake."

9 replies so far   |    Click Here to Add a Reply

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