"The SECURE Act requires annuity illustrations each year for DC plans. There is a calculator on the DOL website for pre-SECURE Act but it is worthless for SECURE Act Assumptions. Specifically, it shows joint and 50% assumptions, but the DOL requires Joint and 100% assumptions for the SECURE Act statements. This is the out of date DOL Link. Any ideas on where to get a free calculator that will produce the SECURE Act assumptions?"

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"Fiscal cash balance plan. 6/30 year end. Plan terminated 6/30/2023. Spouse of owner participant is required to get first RMD due to becoming 100% vested as of 6/30/2023+attaining age 73. He has only 3 YOP so was vested in year 3 which ended on 6/30/2023. There is a possibility that the distribution will be postponed to 2024 as there is a contribution due. [1] When in the first RMD due 12/31/2023 or 4/1/2024 (or prior if distribution done earlier) [2] If due 12/31/2023, because the plan is in termination status, can the RMD be calculated based on account balance?"

"Question for small, 'boutique' TPA firms. Would anyone know or be willing to share the name of a Cyber auditing firm that they used and had a good experience, especially price-wise?"

"Husband and wife each have their own wholly owned business and they are the only employees of their respective companies -- Company A and Company B. The retirement plan is setup under Company A. Her company (Company B) is a participating employer in his retirement plan. I have not come across this situation yet so I had a couple of questions. Together their 401k balances exceeded $250k for 2021 (Company A $160k, Company B $140k), but they did not file a return or extension for 2021. Fast forward to 2022 and they are still above $250k so I would like to file an extension to help prevent an additional $500 late filer penalty for 2022. Before I proceed I had a couple of questions.

1. I assume both of their retirement values is used in determining if they meet the filing threshold. Is this correct?
2. If the wife's company is a participating employer can we still file Form 5500-EZ since all they have are retirement assets? I noticed 5500-SF has a box to indicate a mulitple-employer plan. Not sure if that applies here.
3. Do any special schedules or attachments need to be included in a situation like this?
4. We are not ready to file the 2021 Form 5500. Will filing an extension for 2022 potentially tip off the IRS/DOL that 2021 was not filed and lead to severe penalties? We would like to pursue late filer relief for 2021 and file 2021/2022 ASAP once the extension is mailed in. '

"Seller in an asset sale will have multiemployer plan withdrawal liability triggered by the asset sale. As part of the deal, seller wants to have buyer pay the liability. However, buyer is questioning whether it can obtain a tax deduction for payment of the liability, or whether that would simply be treated as part of the purchase price of the assets and therefore recovered only via depreciation or sale of the assets. 26 CFR Section 1.404(g)-1 provides that a tax deduction is available for withdrawal liability only if the payment satisfies the conditions of section 162 or section 212. This suggests to me that the deduction is not available if the buyer is paying the seller's liability in order to acquire the assets, because this is not an ordinary and necessary business expense of the buyer. But I'm having a hard time finding any specific support for this view. Also, does this mean no one gets a tax deduction for the payment? The buyer doesn't get one because it's not ordinary and necessary, and the seller doesn't get one because it didn't make the payment? Or could this be recharacterized as the seller having received the payment from the buyer and then paying the liability, so that the seller could receive a deduction? (Of course, this would mean that the seller would be deemed to have received more money on the asset sale, but that might be capital gains rather than ordinary income.)"