"With the new Roth Catch-Up Rules for Highly Paid Individuals starting next year, I am trying to make sure that I understand the Rules for recharacterization. I understand that one of the methods for recharacterization is In-Plan Roth Rollovers (if completed timely and the plan permits). My question is this: If a participant is under age 59.5, would this be done as an In-Plan Roth Transfer and the 5-year recapture rule apply?"

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"We administer a 3 participant 401(k) plan. It had always been communicated that all 3 were 33/1/3% partners. For the 2023 plan year (12/31/2023) we prepared and filed a Form 5500-EZ. However, we subsequently found out one of the 'partners' was actually an unrelated employee during the 2023 year. We are thinking of filing an amended Form 5500-SF for the 2023 year, the way it should have been filed. Does anyone think there will be trouble doing this? In other words maybe the IRS will come back and indicate that the original filing did not qualify for an EZ, therefore the amended return (the 5500-SF) is considered late for about 8 months?"

"My plan is top heavy for 2024 plan year. Top heavy minimum is required for current year. However in the mid of the current plan year i.e., on 06/01/2024, plan amended to opt for SH Match contribution (My understanding is that plan is subjected to both ADP & ACP because mid year inclusion of SH contribution). In this case, I think TH minimum is required for non key employees. There is no compensation exclusion in the plan. [1] If there is DOP comp is excluded, how to handle this scenario. [2] If the plan is opted SH provision, it is exempted from TH minimum if it is had SH at the end of the plan year. [3] TH Minimum is exempted whether plan having either SH Match or SH Non elective with no other Employer contribution. I'm curious to here any other points or opinions. If there, it is helpful by providing provision code or IRS documents which it is explaining."