"The DOL template for the SAR for welfare and pension plans includes the two-paragraph blurb on the Paperwork Reduction Act. However, in another location on the DOL website, there is instruction not to include the blurb. I called the DOL Office of the Chief Accountant to confirm which way to approach and they have to do research. Does anyone have advice on which way to approach?"

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"The TSA plan has employees and former employees with different record-keepers than where new money is going. Can they eliminate those other record-keepers, or are they stuck with the money there? What are some possibilities to simplify this for the plan sponsor?"

"Company A and Company B are a parent subsidiary controlled group and both participate in A's 401(k) plan. Company C buys the stock of Company B. Company B immediately ceases participation in the A's plan and becomes a participating employer in C's 401(k) plan. Company C refuses to accept a trustee to trustee transfer of assets and liabilities for B's employees from A's 401(k) plan, nor will C agree to a spinoff and merger on behalf of B's employees. I wouldn't think B's employees would be eligible for termination distributions from A's plan until they terminate from Company B, right? Can Company A spin off the portion of the plan that holds B's employee's balances, terminate it, and pay out the balances even though B is now a participating employer in another 401(k) plan (C's plan)?"

"I know that if a Plan qualifies for a Form 5500-EZ, you don't have to file if the assets are less than $250,000. I believe you do have to file a Form 5500 or Form 5500-SF, even if the Plan is less than $250,000 but I just wanted to confirm. The Plan in question covers: [1] A 40% owner [2] The spouse of the 60% owner Reading the EZ directions, I do believe they fall under the 5500-EZ, I'm just trying to cover my bases."

"Harry inherited his Mom's IRA in 2019. Harry is using the stretch IRA and taking payments based on his life expectancy. Harry is married. In the event of the Harry's death what happens to his inherited IRA? [1] Can his wife roll the funds to her IRA? [2] Can the wife take payments based on her life expectancy? [3] Is the wife deemed a Designated Beneficiary and eligible to continue taking advantage of the stretch provisions?"

"Can a participant have a racehorse as an alternative investment in a 401(k) Plan? A participant would like to purchase part of a racehorse using their 401(k) account and then hold the ownership in the Plan as an asset. Other than keeping all of it 'at arm's length' and watching for obvious prohibited transactions and possible Unrelated Business Income, is there anything preventing this type of alternative investment from being held in a 401(k) Plan?"

"First time filing under DFVC for an EZ. I recall with regular 5500's, you file the 5500 first, then file the DFVC request. Seems unclear with the instructions, other than that you cannot do an electronic filing to get DFVC relief. Mailing address for 5500: Department of the Treasury [IRS] Ogden, UT 84201-0020 Mailing address for 5500 under DFVC: Department of the Treasury 1973 Rulon White Blvd. Ogden, UT 84201 So unclear to me if there should be just the 1 DFVC filing, or a 5500 filing as well?"

"if a plan has been frozen from 1/1/2024 (both accrual and participation are frozen), a participant met all eligibility requirements and should enter the plan on 1/1/2024 if the plan is not frozen. we don't need to test 401(a)(26) test due to SECURE Act 401(a)(26) relief; there is no accrual so no 410(b) test.  I'm just curious -- in this case, should he/she be included in non-discrimination testing due to meeting all eligibility requirements? or he/she should not be included in tests due to 1/1/2024 freeze date? thanks!"

"Suppose you have a 1-person plan with over 250k in assets, so subject to filing a 5500-EZ. Suppose a 5500-SF is filed instead. Is there a PENALTY for filing the SF? Are you considered to have not filed?"

"We took over a retirement plan last year and never received the Roth basis information to calculate if a distribution was qualified or not. The plan is now terminating. I know that a termination does not make the Roth distribution qualified, but what do any of you do if you do not have the 5-year information from a prior TPA or client?"