"Does anyone know what the IRS user fee is for requesting a change in funding method that does not get automatic approval? It is classified as a letter ruling request but the fee schedule does not specifically show changes in funding methods and actuarial assumptions. I see changes in accounting method at $11,500 and then all other requests at $38,000 - big difference."

"I assume further guidance is required, but The Secure Act text states that the lookback 145k compensation for determining the HPEs is from the employer sponsoring the plan. So if a worksite onboards with a PEO and the PEO sponsors a MEP, and the worksite adopts the MEP, then could we make a case that the lookback compensation is based on the compensation under the PEO only? Otherwise, the operational processes of onboarding a PEO, collecting prior-year FICA wages, and possibly year-to-date compensation plus deferrals (if HPE) will be a bigger administrative lift given that employers join PEOs continuously throughout the year. Consideration: Worksite now receives W2 from PEO EIN."

"An individual works full-time as a private school administrator. She receives 20% of her income from her employer and the other 80% from a separate grant organization. Each pay period she receives two checks, one from her employer and the other from the grant organization. Both sources of income are considered taxable income. She is eligible to participate in the employer's 403(b). QUESTION: Can then money from the grant organization be considered compensation for calculating her contributions as well as for purposes of determining includible compensation (415c limit)?"

"Over the years I've seen Plan Sponsors (for ESOP's) setting up sinking funds to pay for future participant benefits. Where do I find the citation/authority for types of assets a plan sponsor can use to fund the repurchase obligation? Is there a specific DOL citation? Treas regulation? I was thinking about this awhile back at a conference for civil/criminal tax matters and one speaker referenced that there's no guidance even on investing in Crypto. Other than a DOL letter/notice (?) with a stern warning that retirement plan investments in 'crypto' may be a breach of fiduciary duties. I don't have the date readily available. I may be conflating the two items as this didn't per se relate to ESOP's. But, could a ESOP trustee invest in crypto as their asset for the repurchase obligation?"

"Professional office with a 401k safe harbor cross tested plan is being sold to larger company, with sale date set for 9/1. All employees will become part of purchasing company with immediate participation in new owner's 401k plan. Both plans are calendar plans. The plan itself is not part of the sale and is intended to be terminated, rather than merged. Both plans also have 1000 hours and last day worked requirements. So there will be no employer ps contribution in seller's plan since no 12/31 eligibility, though they will be making their 3% safe harbor. The new company (I have not seen their plan doc) has informed their intent to provide a ps contribution based on 9/1-12/31 compensation, honoring hours worked all year, but not pay. How is this usually resolved that there seems to be no PS contribution for 1/1-8/31?"

"Employer contributes a specified dollar amount each year to an HRA on behalf of each participant, which money can be used for deductibles and co-pays under its high-deductible health plan. As a group health plan, the HRA is subject to COBRA, but the premium is not entirely clear. I understand that there are a couple methodologies for determining the premium for COBRA purposes (e.g., actuarial method and past-cost method), but is there an argument that the premium is the employer contribution itself on top of which an administration charge up to 2% could be added? It does not seem that former employees should be eligible for continued employer contributions to the HRA; that should be limited to current eligible employees."

"Participant died in 2022 prior to his required beginning date. Surviving spouse is sole beneficiary and current employee and would like to roll over his balance into her account in the same plan. Assuming the plan allows this, any concerns? Would she have 10 years to fully distribute the amount attributable to the deceased participant or would it be consolidated with her balance and subject to her own RMD requirements?"

"Need some help. Plan has 1 year of service, 1000 hours and dual entry. FTW Document - Rule of Parity & 1 year hold out is not elected i have an employee hired 8/2020 termed 3/2021. Worked over 1000 hours Rehired 8/2022 Since she worked over 1000, would she enter on rehire date? Appreciate your help. Thanks!"

"2024 increases to $7k. Suppose plan currently uses 1K. Can the plan operationally go ahead and use the 7K for 2024, or must it amend to 5k, which then increases to 7k? The latter seems absurd, but an interesting question."