"If a company paid a qualified plan expense directly (i.e., audit fees), are they able to be reimbursed from the plan's forfeiture money? I have had some clients that have done this with no problem, but one recordkeeper is telling a client it is not allowable. Thoughts?"

"The CPI-U for July, August, September of 2025 are all published with values of 323.048, 323.976, and 324.800 respectively. Based on Tom Poje's spreadsheet, the dollar limits for 2026 will be: NOT Official via any IRS pronouncement yet, of course: Deferral limit: $24,500 (up from $23,500) Catchup: $8,000 (up from $7,500) (Super-Catchup, age 60-63 = $12,000, up from $11,250) Compensation Limit: $360,000 (up from $350,000) Annual Addition Limit: $72,000 (up from $70,000) DB Limit: $290,000 (up from $280,000) HCE: $160,000 (unchanged) Key Employee: $235,000 (up from $230,000) the 2026 HPI comp number should be $150,000 (up from $145,000) It's unclear but my guess is that means in 2027 we look at comp over $150,000 paid in 2026 for determining HPI's in 2027. The official taxable wage base for 2026, announced by SSA, is $184,500 (up from $176,100)."

"For the tax law that a higher-wage participant's age-based catch-up deferrals must be Roth contributions, the unadjusted Section 414(v)(7)(A) amount was $145,000. For 2024, the first tax year Section 414(v)(7) applied (even if not enforced), a participant was Section 414(v)(7)-affected if her 2023 wages was more than $145,000. Despite the IRS's nonenforcement relief, the IRS published the Section 414(v)(7)(A) amount for 2025: 'The Roth catch-up wage threshold for 2024, which under section 414(v)(7)(A) is used to determine whether an individual's catch-up contributions to an applicable employer plan. .. for 2025 must be designated Roth contributions, remains $145,000.... I read Section 414(v)(7)(E)'s (the adjustment provision's) reference to 'the $145,000 amount in subparagraph (A)' as referring to Section 414(v)(7)(A)'s reference to 'wages. .. for the preceding calendar year[.]' So, a participant will be Section 414(v)(7)-affected for 2026 if her 2025 wages was more than $150,000. BenefitsLink neighbors, do you read the law the way I read it? Without waiting for an IRS release (which might be shutdown-delayed), many employers, plan administrators, and service providers want now the estimate -- even if one explains it's not yet official -- to communicate with might-be affected participants and to help payroll managers prepare to identify 2026's affected participants."

"For years, John Feldt has generously given us inflation updates using Tom Poje's spreadsheet. But that spreadsheet might not do everything we now use. That's for at least a few reasons: The spreadsheet likely was designed for to-be-adjusted items then known, not for laws Congress enacted later. Not all adjustments, even those for points a retirement-plans practitioner cares about, fall in with Section 415(d)'s regime; many refer to an adjustment regime under Internal Revenue Code Section 1 or something else. Even beyond those points, the spreadsheet might have been designed based on expected users' business interests. Some BenefitsLink neighbors already have asked about adjustments not in the spreadsheet. Let's crowdsource some recent measures."

"If a 'Highly Paid Individual' goes over the 415 limit but NOT the 402g limit, their catch-ups need to be coded as Roth. [1] What happens if the discretionary profit sharing that puts them over is deposited after the end of the year? Is the only option the Roth conversion correction? [2] Does anyone have any ideas for how to handle a plan that is contributing 15% of pay throughout the year, where they will hit the 415 limit during the year well before they hit 402(g)? I almost wonder if we should tell these Highly Paid Individuals to contribute $7,500 of Roth first to avoid any issues. These seems like it's going to be a real challenge for some plans. Obviously it is few and far between, but when it applies I think its going to be a pain. Curious if others have any grand ideas."

"If a new 403b is subject to mandatory auto enrollment, can that plan still qualify as ERISA exempt? I know the question has been asked -- has it been answered?"

"Where a see-through trust is named as an IRA beneficiary, may IRA distributions be reported on the 1099R directly to the trust beneficiary? This is particularly key where the beneficiary is younger at a low income tax bracket, the trust grantor intends to control the IRA fund flows to the trust beneficiary, and to avoid the trust's higher income tax rates while retaining IRA distributions in the trust. Reporting 1099R directly to individual beneficiary seemed to be the practice when see-through trusts first came out in early 2000s, but that reporting has changed over time?"