Message Boards Digest

October 9, 2023

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

User 282823 created a topic in Relius Administration

Using Relius Online In-Service, Hardship and Loan Automation for Participants

"We are trying to utilize the online capability of having participants request Hardships and In-Service Distributions as well as Loans directly through the website. Is someone able to point us in the right direction on the procedures Relius provides in order to get this setup accurately with all the specific distribution/loan provisions that a plan would have?"

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Below Ground created a topic in Plan Terminations

Retroactive Plan Termination

"We have a defined benefit plan that is seriously underfunded, with a required contribution needed for 2022. Benefit accruals have since been, prospectively, frozen with appropriate advance notices. (This was actually done several years ago.) I also note that the plan is NOT covered by PBGC. One thing that the Client is being advised to do is to have the Plan be deemed terminated retroactively. For example, amend the plan NOW to say the plan was deemed terminated as of 12/31/2021. Is this allowed?"

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TinaW created a topic in 401(k) Plans

5500 Count: Terminated Participants with Zero Beginning Balance

"I have a plan that was audit level in 2021. They are current at 101 participants. Two participants terminated in 2021 has a zero balance on 1/1/2022, but received lost earnings within the year. Datair is counting them in the 2022 beginning participant count. Since they didn't have a beginning balance, should they considered a participant for the Form 5500 count?"

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ill created a topic in 401(k) Plans

Contributions Deadline for Solo 401(k) as Sole Proprietorship

"I am trying to understand if contributions (Pretax, Roth, and after-tax, also known as Mega Backdoor Roth) to a solo 401k can be made before the tax deadline and not strictly by the end of the year for a Sole Proprietorship. I was reading that contributions can be made before the business tax deadline, except for the Employee contribution part, which should be made before the end of the year: While employee and employer contributions may be extended until the company tax return deadline, you will typically need to file a W-2 for your wages (e.g. an S-Corporation) by January 31st, 2023. The W-2 will include your wage income and any deduction for employee retirement plan contributions will be reduced on the W-2 in box 12. As a result, you should make your employee contributions (up to $20,500 for 2022) by January 31st, 2023 or you should at least determine the amount you plan to contribute so that you can file an accurate W-2 by January 31st, 2023. If you don’t have all or a portion of the funds you plan to contribute available by the time your W-2 is due, you can set the amount you plan to contribute to the 401(k) as an employee contribution, and will then need to make a said contribution by the tax return deadline (including extensions). I am a bit confused about the W2 part. As a Sole Proprietorship, I do not have a W2 form (I give my customers a W9 form when making contract work). Does it mean I can make the Employee contribution part before the tax deadline? Also, can the Mega Backdoor Roth be done before the tax deadline as well?"

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