"Sole-prop, activity commenced late in 2021, 2021 Schedule C is negative, 2022 Schedule C is 150K, 2023 Schedule C is 150K. What is my 3 year average comp for 415 limit purposes? Is it 150K or is it 100K? Is there any specific guidance on that type of situation?"

"Is a free-standing HRA that only provides benefits to retirees subject to PCORI?"

"The client has a Schedule C with $475,000 net income. He is contributing $55,000 to a 401K and almost all of his QBID is phased out. He also has $140,000 pension income plus some investment income. Charitable contributions are approximately $75,000. MFJ, 69 years old. I would like for him to adopt a DB pension plan and defer a large portion of his net profits. My questions are as follows: [1] Should he elect c-corp tax status? If so, does he need to pay himself a salary? I am thinking of a $200,000 DB contribution and a $200,000 salary, leaving some cash in the c-corp to be taken as dividends in later years (once fully retired). Is there a minimum salary that he must pay himself? [2] If c-corp status is not elected, can he still set up a DB plan for himself even though he is not an employee? Does he pay SE tax on profits before the contribution, or on profits net of the contribution? [3] He has not yet filed his 2023 returns. Is it too late to set up and fund a DB plan for 2023? I would appreciate any feedback on this. New territory for me."

"We have a private equity client who wants to allow IRAs (self-directed, with a custodian) to invest in the fund. Several years ago, the fund was told that, due to new fiduciary rules/requirements (this was an Obama-era rule, they think), there were too many unknowns and they shouldn't allow IRAs to invest in the fund. I know we have to watch out for the 25% threshold, but, other than that: [1] Any idea what fiduciary rule would have resulted in prior counsel advising we don't accept IRA investment? Has anything changed to make this less of a problem now? [2] Any other concerns we should keep in mind regarding IRA investment in the fund?"

"Had a participant in RMD status die in 2023, and her account was to be split amongst her five daughter beneficiaries (which, ugh, but at least there was a valid beneficiary form!). Three of the beneficiaries took their distribution in 2023. Each share of the account is <$3K, and the plan has a $5,000 (I guess $7K now) forceout limit. Presuming the remaining two don't elect to take their distribution in 2024, do we have any options? Of course, we need an RMD based on the 12/31/23 balance, fine. But can we force these amounts out of the plan? The recordkeeper is ready to do so -- they don't have any problem sending it to an IRA custodian. Just not sure that I'm 100% comfortable going along with that."