"IRS audited clients retirement plan an ESOP. In the USTC declaratory action retirement plan is disqualified. Typically on an appeal from USTC the bond amount determined from tax deficiencies. However since the declaratory action doesn't have a tax deficiency how do you proceed with appeal? File a bond with $0? What companies have you used for appeal bonds?"

"I've got a PEO MEP. One of the members terminated their service agreement with the PEO effective 1/31/24. Is there some kind of timeframe or requirement that their assets have to leave the MEP? In case it matters: > There is a SHNEC deposited after we calculate it EOY. > They have not yet made arrangements for their portion to be spun off (no TPA or asset custodian chosen, etc.). > They have also not made arrangements for anyone to administer their spin off going forward, so I told them that they have to cease deferrals at least temporarily (because there is nowhere to submit them). I'm not 100% sure that is correct; is there a better option? I'm presuming this won't affect SH status since they will still all get 3% of full year comp when someone does the annual 2024 administration. Obviously, the PEO sponsoring the MEP would like them gone as soon as the product platform can get them out."

"Under HIPAA, a business associate must notify a covered entity health plan no later than 60 days from the time it discovered a breach of unsecured protected health information. If a business associate has, say, thousands of covered entity clients and discovers that only a few participants of only a few of the covered entity health plans are affected by a breach (and the business associate does not know which ones until later), when does that 60-day window start? Does it start when it determines which specific covered entities are affected? Or does it start when it discovered the breach (which would require that it notify all of its clients, most of which would ultimately be unaffected)? I could not find any HHS guidance on point."

"Does anyone have a good website for the actual text of internal revenue code, specifically that incorporates the changes from SECURE 2.0? The ones I usually use, such as the Cornell Legal Institute don't have those sections updated yet, and I don't know when they will be. So when I want to see how the updated language works with the prior language, I have to have both the text of SECURE 2.0 open as well as the code as it was pre-SECURE 2.0. Its getting a little old. When I want to really understand something, I do try to read the source material, not just other's articles and interpretations, so having an updated integrated source of the IRC would be so helpful."

"I own a LLC (taxed as S Corp) that offers a SIMPLE IRA to employees and myself. I also have additional sole proprietary self-employment income from other activities (no employees, just me). Can I setup a SEP IRA to put some of that income into a retirement account?"

"I know adopting a SH plan for 2023 is out. What about just a PS plan and then converting it to a SH plan for 2024? That should be perfectly fine, right? Date of adoption would be say today, 2/2/24 Effective date I could say 1/1/2023?"

"Does the successor plan rule in Treas. Reg. 1.403(b)-10(a)(1) apply to a church 403(b) Plan that contains elective deferrals? I do not see anything exempting a church plan from being subject to that rule."