"Hypothetical: 2022 retroactive CB plan to be set up. Potential sponsor already filed 2022 corp return but will amend for reasons other than this but wants to include if possible. In CA we have an automatic extension for all counties due to weather except 2 (client located in county under extension). We have time to file 5558 still. Rev Rule 66-144; 1966-1 C.B 91 seems to support this: 'Section 404(a)(6) of the Code provides that a contribution for a taxable year made by a taxpayer reporting on the accrual basis shall be deemed to be made within such taxable year if paid within the time prescribed for filing its return plus any extension of time in which to file. Therefore, a contribution paid within an extended filing period is deemed to have been made during the taxable year. Thus, a contribution made during such extended period, as provided for under section 6081(b) of the Code, is deemed to have been made during the taxable year regardless of when the return is filed.' Guess the question is does the filing of the 2022 corp return trump the automatic extension granted for CA thru 10/16/23?"

"The employer's HSA plan starts September 1, 2023. Can an employee contribute the maximum allowed HSA contribution for 2023 and 2024?"

" 'Simple' question: the instructions in IRS Publication 560, Retirement Plans for Small Businesses, say that contributions to a SIMPLE IRA will not affect the amount an individual can contribute to a Roth or traditional IRA. However, I thought that if you participated in a qualified retirement plan, that affected the deductibility of contributions to a traditional IRA? In addition, I have a question re contributions to IRAs. On page 7 of publication 590-A, it says a trustee or custodian generally cannot accept contributions of more than the deductible amount for the year. But I thought folks may make nondeductible contributions to traditional IRAs, subject to the dollar limits and applicable filing status limits?"

"IRS Publication 560, p. 15-16 says an employer must make salary reduction contributions to a SIMPLE IRA within 30 days after the end of the month in which the amounts would have otherwise been payable to the employee. Then it says 'Certain plans subject to DOL rules may have an earlier due date for salary reduction contributions.' What are these 'certain' plans? Is this referring to the DOL safe harbor rule that provides the employee contributions deposited to retirement plans with fewer than 100 participants must be deposited within 7 business days following receipt or withholding by employers? When would the latter not apply since SIMPLE plans apply to businesses with 100 or less employees?"

"I'm supposed to be able to dump into Excel or whatever format a listing of all plan provisions. It's under 'Data Export'. Anyone know how to do that? I cannot get it to work. I'm waiting for Relius to provide some direction but figured I would ask y'all! FYI I am trying to very efficiently figure out which clients dont have Roth or who are affected by LTPT rules."

"John Doe owns 100% of corporation A, Sponsors Plan (X) -- calendar year plan. During 2021 calendar year, John sells ASSETS of corporation A to Edward Doe. Edward has corporation B -- keeps the same corporate name, but now under new employer id# (he's 100% owner) and assumes the assets and liabilities of plan X and sponsors the plan. The former owner John Doe continues as a non-owner employee in corporation B. For 2022, John would appear to be a Key employee, since for part of the PLAN year containing the determination date (2021), he owned 100% of the corporation sponsoring the plan, which was subsequently taken over by corporation B. Have I got that right? Then in 2023, he's a former key, and his balance is excluded from the top heavy test. Have I got that right?"

"We're having a difference of opinion in my office regarding whether the eventual grant of a meaningful benefit (via an 11(g) amendment after the year ends) is an appropriate actuarial assumption for purposes of running the beginning of year valuation. For example, when doing the 1/1/23 valuation for a cash balance plan the actuary is aware that less than 40% of participants will be accruing a meaningful benefit. The actuary determines that 8 additional participants, who would not otherwise accrue any benefit during 2023 (due to a current classification exclusion), will need to accrue a meaningful benefit and includes them in the valuation on the basis that that reflects his best estimate of plan liabilities. Others believe that the meaningful benefit accrual for those participants should not be reflected as of 1/1/23 since there is no current amendment granting the accrual. It's possible that when the amendment is adopted the meaningful benefits may be granted to different participants. As an aside, the increased contribution for the additional normal cost (which is about 10% of the overall normal cost) would still be within the plan's maximum deductible limit even without these benefits. What do you think? Opinions and/or specific citations would be appreciated."

"Looking for a citation for the following: For a new entrant into the plan who receives the safe harbor contribution for only part of the year, i.e. while a participant, the top heavy contribution should be for the entire year and thus, such a participant would require an additional top heavy contribution. Participant entered in July, but received a safe harbor from date of participation."