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June 11, 2025

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Dalai Pookah created a topic in Retirement Plans in General

IRS Auditor Asking for Participant Drivers Licenses

"For the first time, in an IRS audit, the auditor requested copies of participants' drivers licenses to verify dates of birth. Has anyone else experienced this? While this is a creative way to verify DoB, it seems to be sort of an intrusion as I don't believe most employers capture this information. They may visually verify the license when completing the I-9, but not capture the image. Just curious to see if this is a new ask, generally, or merely confined to one office."

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MATRIX created a topic in Governmental Plans

Tax Reporting for Transfer to Purchase Service Credits

"I was wondering if a 1099R is needed to report a transfer from a governmental 401k plan to a governmental defined benefit plan to purchase service credits? Form 1099R instructions state to not report a transfer but appear to apply in the context of 403b and 457b plans."

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Connor created a topic in 401(k) Plans

Discretionary Match

"Is it possible for a plan with a safe harbor match to also offer a discretionary match and still retain its safe harbor status, i.e., avoid ADP/ACP testing & TH mins? In other words, a triple stack match without a fixed match -- could that still be considered a safe harbor plan? If so, what would be the limitations on the discretionary match?"

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Carol V. Calhoun created a topic in Retirement Plans in General

Corporate Acquisition/Plan Termination/415

"I'm trying to figure out the rules when a plan is terminated just before the employer is acquired, and its employees are thereafter covered by the acquirer's plan.

"Let's call the acquired company A and its plan, Plan A. The acquiring company's plan is Plan B. The IRS site says that the 415 limit is prorated for a terminating plan, but not in the case of an individual who joins a plan late in the year. And of course, plans of a single employer are combined.

"In this case, presumably Plan A must apply a prorated 415 limit to contributions made before its termination. But because the employees of A have been employed by the same entity all year, and Plan B did not have a short plan year, presumably Plan B must combine its benefits with those of Plan A in calculating the 415 limits for Plan B.

"But does the reverse apply? Must Plan A combine its benefits with those of Plan B in calculating the 415 limits for Plan A? Common sense would seem to say no. Plan A had a short plan year, and no contributions were made to Plan B on behalf of A employees during that short plan year. But I haven't found authority directly on point."

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