"U S. Holding company owns several subsidiaries and just purchased a company in Canada. The employees of the Canadian subsidiary are still paid via payroll through the Canadian subsidiary, but the company is funded via the U.S. holding company. Can the U.S. holding company include the employees of the Canadian subsidiary in their 401(k) plan? My gut says no because their income wouldn't appear on the surface to be US sourced, but I'm on the fence. Anyone run into this before?"

"Offset DB plan terminated. Due to offset, out of 20 participants, only 2 owners have benefits. all others' benefits are offset by DC plan. Document states, excess is allocated to the plan participants. Questions raised and discussed (asking them as they are):

• Assuming the excess to be allocated to the participants, do all need to get an allocation?
• If yes, can there be any offset?
• Do both owners need to get an allocation or is it possible to give only one owner the additional allocation? Neither owner is at 415 limit.
• Can a qualified replacement plan (QRP) be set up now, plan provisions be amended for reversion to employer and excess transferred to it? Provisions have been around for more than 5 years.

"Any other suggestions?"

"A plan is terminating in 2025. If a participant is over [73], do they have a Required Minimum Distribution (RMD)? What if funds are rolled over into a 401(k) plan?"