"Is there a limit to the amount of rollovers a participant can take, using the 60-day window to repay the distribution/roll it into an IRA?"

"A client asked about the following situation: Employee becomes a highly paid participant ('HPP') for 2027 subject to the mandatory Roth catch-up rules. Although the plan has adopted a 'deemed Roth election' feature, employer never provided notice to the employee that she was an HPP for 2027 and, thus, was required to make catch-up contributions on a Roth basis. HPP makes pre-tax deferrals in 2027 up to the 402(g) limit and the statutory catch-up limit.

The client asks 'what is the required correction?' My thoughts are as follows: The client cannot move the pre-tax catch-up contributions to the HPP's Roth deferral account, because the deemed Roth election feature does not apply (due to the fact that the HPP was not given an opportunity to opt out of the deemed Roth election feature). In this case, the pre-tax catch-up deferrals (and earnings) are distributed to the HPP under the mandatory Roth catch-up regulations. However, I don't think this is the full correction. I believe there has been a failure to provide the HPP with an opportunity to elect and make catch-up contributions. Accordingly, this error must be corrected by the employer making a QNEC as set forth in Rev. Proc. 2021-30, Appendix A, Section .05(2)(g)(4)(a) ('Improperly excluded employees: catch-up contributions only'). Have I thought this through correctly?"

"I have a client that would like to offer individual brokerage accounts (as an alternative to investing in a platform) for accounts over a certain threshold of assets (let's say $50,000+). Is this discriminatory?"

"Have been the EA for about 25 DB plans (mostly stand alone) for a TPA where we billed the TPA after we did the valuation which was a mutual understanding though nothing in writing. For 10 years payments came but early 2024 they stopped and have been sporadic since though valuation work done and forms submitted through 2024 plan year. Last partial payment was in July and outstanding fees are up to $30k, most for 2 plan years. What would be ethical ways to proceed to get paid (assuming will not be doing any further work for this TPA and not suing based on past experience): a) contact plan sponsors directly regarding the situation, b) provide names of plans to another TPA with the expectation they would contact the plan sponsors, c) amend 5500 filngs for unpaid years (since we have filing authorizations) removing the SB, d) 1099 the TPA for the $30k, e) publicly name the TPA (like on this message board) as a warning to others? Are none, some, or all of these worth a try or are there better options?"

"Interesting situation here. A new plan in 2025. Long story short, they withheld deferrals from many payrolls and did not submit. They have since submitted, using DOL calculator for interest, and will file with the DOL under VFC program. As part of the VFC filing, they will submit a copy of the 5330 proving payment of the interest. So, must this 2025 5330 filing, for the 2025 year, be submitted electronically? In July of 2025, the IRS said this: Treas. Reg. 54.6011-3(a) requires a taxpayer to file Form 5330, Return of Excise Taxes Related to Employee Benefit Plans, electronically for taxable years ending on or after December 31, 2023, if the filer is required to file at least 10 returns of any type during the calendar year that the Form 5330 is due. Treas. Reg. 54.6011-3 (b) and Instructions for Form 5330 also provide, on an annual basis, exclusions from electronic filing requirements in cases of undue hardship. Form 5330 can be filed electronically using the IRS Modernized e-File (MeF) System through an IRS authorized Form 5330 e-file provider. Currently, IRS has only one authorized e-filing provider for the Form 5330. As a result of the lack of authorized e-file providers for the Form 5330, the IRS has determined that a filer is permitted to file a paper Form 5330 for the 2024 taxable year. The filer should document that the reason for not filing electronically and filing a paper Form 5330 is the lack of authorized vendors. Seems to me that since this 5330 is being filed under the same timeframe and basic circumstances, that this waiver should prove valid and allow paper filing. Thoughts?"

"Participant was 0.3% partner in law firm in 2024. Still working. No ownership in 2025 Turns 73 during 2025. Is he required to take an RMD which would be due 4/1/2026?"