"Client sponsors a standalone profit-sharing plan, family only; six individual accounts with Vanguard. Spouse thinks she know all, saw something online that allows a rollover to Roth IRA, gets husband, over 59-1/2, and plan allows for 'in service' to rollover all his Vanguard accounts to individual Roth IRAs, without paying any taxes. To my knowledge you can't rollover unless taxes paid, but of course, could be wrong."

"Participant terminates in 2025. Plan provides termination distributions following the close of plan year in which termination occurs (and no partial withdrawals for termination distributions). Therefore termination distribution can occur in 2026. Participant has a Participant Loan balance at termination. Loan Programs states it is due and payable upon termination of service. 

"Q: Since the Participant is not yet eligible for a termination distribution, and further the plan does not permit partial withdrawals for Termination, is the loan balance a 2025 'deemed distribution' due to default (end of calendar quarter following quarter first payment is missed), which must be carried on the plan's books with (phantom) accrued interest until such time the Participant requests a termination distribution presumably in 2026? Or is it a 2025 'plan loan offset' since the Participant is terminated even though the Plan does not permit a termination withdrawal at this time, or partial withdrawals for terminated participants? Concern with the latter: Treas. Reg. Section 1.72(p)-1, Q&A-13(b) provides that, in the event of a 'plan loan offset', the amount of the account balance that is offset against the loan is an actual distribution for purposes of the Internal Revenue Code (IRC), not a deemed distribution under IRC Section 72(p). The concern being an actual distribution is not yet payable by the plan -- it is not clear to me if this would (inadvertently) be an operational failure."

"I have a 401k plan where the investments were ppt directed until October 2024. The plan switched to 'pooled' account and is now owner only. Do I include the 5500 codes (2G) for ppt directed on the 5500SF since the plan was ppt directed for a portion of the year?"

"We have a spinoff of a grandfathered PE from a grandfathered plan into a new spinoff plan. I don't think MEP/PEP/SEP matters here but help me if that's not right. That spinoff plan will be 001 for the EIN with a 1/1/2025 original effective date. Assuming that's the right original effective date for the spinoff plan (as compared to the original adoption date of the PE into the grandfathered plan…) Where/how does the document distinguish this grandfathered 1/1/2025 plan from a new non-grandfathered 1/1/2025 plan? In other words, where/how do we inform the participants/IRS/the world that this plan is NOT subject to the EACA mandate?"