"Client has hit some hard times, but wants to continue to benefit the employees (at least for now). They reduced the contribution to the owners in 2023, but now need to reduce their contributions again. Generally I know you can't change the benefit annually. However, if the employees stay the same and it's just the owners who are taking a reduction (possibly as low as $0), would that be viewed as acceptable? I don't see an issue, since it's only the HCE who are being negatively impacted."

"The exclusion from income for an employer's contribution to a Trump account is Internal Revenue Code Section 128. Internal Revenue Code of 1986 (26 U.S.C.) Section 125(f)(1) defines, generally, a 'qualified benefit' as 'any benefit which, with the application of subsection (a), is not includible in the gross income of the employee by reason of an express provision of this chapter [Sections 1®1400Z-2] (other than section 106(b), 117, 127, or 132).' After Section 128's effective date and assuming fitting timing regarding all plan and tax years, could an employer's contribution to a Trump account be a qualified benefit under a Section 125 plan?"

"In 2026, if catch-up reclass is required for an ADP test failure, do we need to convert the catch-up to Roth for employees that are HCE due to compensation? What is a plan does not allow for Roth, does the reclassed catch-up get refunded instead?"