"A client wants to offer a generous reimbursement program for surrogacy benefits. (Fertility is already well-covered under their health plan.) The reimbursement program would not reimburse any medical expenses of employees/spouses/partners/dependents. However, it would reimburse medical expenses of the unrelated surrogates. Is there a reasonable argument that this is NOT a MEWA? What are the risks here?"

"We have a situation where force out amounts from qualified plans were rolled over to a non-Roth IRA and the rollover contained after-tax amounts and pre-tax amounts. When the IRA owner later takes a distribution, how does this get tax reported on the 1099?"