"I have a client who has not been able to process his payment since Friday, and has a tried a few times. Anyone know if the site is down? He finishes entering all of his info on the DOL side, he goes to the IRS pay.gov site and enters all of his credit card information and then it tells him there was an error processing."

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"I have a client who owns 40% of 3 car dealerships, the other 60% is owned by his father-in-law (30%) and uncle-in-law (30%). He then owns 100% of 4 other dealerships. He has two 401(k) plans that we administer, one plan covers the entities he owns 40% and the other plan covers the entities he owns 100%. With respect to this situation I have the following questions: [1] I have done controlled group analysis and have determined that the 3 dealerships he owns 40% are not part of the same controlled group as the entities he owns 100%; does this appear to be right? Am I missing anything? I don't think affiliated service groups applies since a car dealership isn't a service entity and I don't think a management group applies because he gets paid a W2 from each dealership, he doesn't have the dealerships pay a management company that he owns (also, I am not sure if it is a requirement for the business to be a service company to be part of a management group). [2] We have been allocating a profit sharing contribution for each plan and since I think both plans are unrelated he has a separate 415 limit in each one. One plan he does his max deferral and gets a match and maxes out to the 415 limit via profit sharing and then the other we just allocate a profit sharing contribution and max out to the 415 limit. However, he just turned 50 in 2022 so he is eligible for catch-up. My question is, if we had him fund the normal 402(g) limit (22,500 for 2023) to one plan without catch-up and then fund the catch-up (7,500) to the other plan, could he fund $73,500 to each plan? It seems wrong because he is basically using the catch-up limit twice (each plan would be using 7,500 of catch-up) but he isn't going over the 402(g) limit (he would only be funding 30,000 total in deferrals between both plans)."

"To keep this simple, I will use two HCEs and two NHCEs that are being tested for nondiscrimination. All 4 employees are non-excludable. Can one HCE & one NHCE receive an allocation, and the other HCE and NHCE receive $0.00? 410(b) test would be 100% Each employee is in their own group, and the plan does not have the SHNEC to trigger the minimum gateway."

"ERISA Section 502(c)(2)'s civil penalty for a failure to file an annual report is $2,586 per day. 88 Fed. Reg. 2210, 2219 (Jan. 13, 2023). If a plan's administrator is off by one year and three weeks, that's about $1 million."