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October 11, 2024

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

Tom created a topic in 401(k) Plans

Is Federal Tax Withholding Required on RMD?

"I realize record keeping platforms generally indicate 10% will be withheld unless the participant elects something different (implied higher.) But can a participant elect zero withholding on an RMD?"

3 replies so far   |    Click Here to Add a Reply

Basically created a topic in Distributions and Loans, Other than QDROs

Roth Deferrals and Roth Conversions

"Simple questions for a cheat sheet I am making....

  • If a participant makes ROTH deferrals, that money has its own 5 year clock... Yes?
  • If a participant continues each year to make ROTH deferrals, does that new money use the original clock start date?
  • If a participant makes an in-plan ROTH conversion, I know that has its own start date. And every time they do an in-plan ROTH conversion the conversion gets its own start date. Here are the questions... all in-Plan ROTH conversions need to be in their own investment account... That account can be on paper... correct? My system will track it, that's all that matters, correct?"
4 replies so far   |    Click Here to Add a Reply

DocumentDiva created a topic in 401(k) Plans

Hurricane Relief

"I work for a TPA Firm, and our main office address is in Atlanta, GA and I'm in Florida and we have others in South Carolina. The entire state of Georgia, Alabama, North Carolina and South Carolina and parts of Florida were given tax relief for victims of Hurricane Helene under Hurricane Helene Notice IR-2024-253. I would assume our clients could file under the Hurricane Relief extending the due date until May 1, 2025, even if they are not in the states with full relief because we are practitioners in the areas that were impacted. MOST of our client are in GA, FL, SC & NC. Now with Hurricane Milton I believe the entire state of Florida will now be given the same relief and not just certain counties in Florida impacted by Debby and Helene. Of course, we aren't advising this however, it's the reality that clients don't all have power or capacity to deal with 5500's at the moment. I'm curious how other TPA firms in the impacted areas are handling this."

No replies yet   |    Click Here to Add a Reply

Executor created a topic in 401(k) Plans

401(k) Distribution After Death

"I am the Executor of an estate. Immediately post death the wife send in the beneficiary form to her spouses company. The decedent had been the plans administrator and never send in his beneficiary form for two reasons [1] He had discussed with his wife he wanted some of the money to go to his mother and the wife (third wife- with a prenuptial agreement) refused to agree to allocate some of th 401K money to her husbands mother. [2] since she wouldn't sign we refused to send it in because his believed his prenuptial agreement would direct all the money to his estate. The company is small -only two employees. when the man diet, the other employee. wss then named to Fiduciary for the business. He inaccurately signed a new distribution form and transfered the money to the wife's 401K. The Fiduciary has been made aware of this error (which was conveniently hidden). Now what do I do to get that money to the decedents estate?"

2 replies so far   |    Click Here to Add a Reply

Insurnacegirl555 created a topic in Health Plans (Including ACA, COBRA, HIPAA)

COBRA for Actively Covered Open Enrollment

"If an active employee has medical coverage but does *not* qualify for coverage when its time for open enrollment, do they qualify for cobra offer? In this case, the business is using the ACA one year lookback measurement to determine eligibility and the variable rate employee dropped to around 20 hr/week so they will not qualify for 2025 coverage. But, they do have coverage currently. Should a COBRA offer be made effective 1/1/25 in this scenario? Or, is it not a qualifying event that they no longer qualify during open enrollment due to dropping under required number of hours?"

2 replies so far   |    Click Here to Add a Reply

John K created a topic in 401(k) Plans

Unlawful to Take In-Service Withdrawal Before 59.5?

"Can someone please help cite IRS code that states it is unlawful to take in-service withdrawals of elective deferrals and safe harbor funds before age 59.5?"

2 replies so far   |    Click Here to Add a Reply

Tom created a topic in 401(k) Plans

Revised ADP Test Over-Refunded

"A client provided a census file and we ran the ADP test and processed 3 corrective distributions By March 15. The plan auditor discovered in August, there was incorrect compensation on the census file. The 3 with the refunds ended up with higher wages. Of course then it meant the the issued refunds were too high. Approximate example: correct refund should have been $5500 but $7500issued. Two of the 3 are over 59 1/2 and so their excess can be considered in-service under the terms of the plan. But then there is the younger HCE. Do you believe this must be corrected? We could have the participant return funds and have the record keeper change the 1099-R that will come out in January if that's even possible. I'd rather avoid that. Thoughts -- thank you. Tom"

No replies yet   |    Click Here to Add a Reply

BG5150 created a topic in Form 5500

Plan Switched Carriers in 2023 -- Do I Need Attachment Per 4j on Sch H?

"Plan assets transferred from Carrier A to Carrier B in 2023. Auditor is looking for reportable transactions (those over 5% of assets). I've never completed that for any transfer between carriers before. Have you? I've had several other plans change carriers mid-2023 and none of them were asking for this. The exception is an individual account where the participant directs the transaction, but the participants in these cases don't direct these transfers. Do I have to attach a schedule per 4j on the Schedule H?"

No replies yet   |    Click Here to Add a Reply

SadieJane created a topic in Defined Benefit Plans, Including Cash Balance

Does High 25 Restriction Apply to Union DB Plan?

"Does anyone know if the 'high 25' rule (certain distribution restrictions to HCEs in a DB Plan) applies to a collectively bargained plan? I have an actuary who is suggesting it does not apply but am not finding any authority for that."

2 replies so far   |    Click Here to Add a Reply

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