"We have a Plan that has immediate eligibility for the 401(k)/Safe Harbor Match, but we are looking to do 21 & 1 year for the Profit Sharing & Cash Balance portions. I know the Safe Harbor Match (for everyone) gets factored into the 6% maximum deductible contribution for the employer contributions. That said, for the people who are eligible for the 401(k)/Safe Harbor, are they factored into the rest of the testing for the PS/CB? For instance, when we are doing the rate group testing are those people factored in? Or do we only test for the people who are eligible for the Cash Balance Benefit?"

"Lawyer gets 1099-R income of about $1 million from a partnership in which he has no equity and wants to set up a solo DB plan. Twist is that the law firm principal partner also owns a Title search company that employs the lawyer who gets a W-2 from it and makes 401(k) deferrals. Leaving aside any link between the partnership and the title company (don't know what exact ownership percentages are) would there be any issues with the lawyer setting up a solo DB plan with the Schedule C he gets with that 1099-R income?"

"VFIAX = the 'Vanguard 500 Index Fund Admiral'. I have a client for whom I'm calculating a marital portion of an old 401k containing that single investment. That 401k has undergone some mergers and recordkeeper changes such that historical statements for individuals are no longer available. The parties agreed to ballpark the present value of the premarital balance, and to estimate that premarital balance by working backward from a later balance by subtracting annual fund overall returns on that single investment. Whether or not this is the right/smart way to approach it is not the issue, finding the historical fund returns is. (I'm a lawyer rather than a math person, but I can run a spreadsheet with reasonable competence.) The annual returns sought on that VFIAX fund as a whole are for the years 1997-2003. I have been able to locate overall fund returns back to 2003, but not before that, and would be grateful if anyone happens to have those. Suggestions and criticisms are also welcome."

"A DB participant terminated at age 60. Was entitled to his benefit at the plan's NRA of age 62. Did not get paid his benefit until age 74. Actuarial increases are bring given to reflect the benefit payments that were not made for the period of age 62 until age 74. Question: The increased a accrued benefit at age 74 is $2,950. The participant's average monthly comp was $1,964. Is this increase up to 2,950 that is greater than his avg comp allowed or is the increase capped at $1,964, his average monthly comp (as cannot increase the benefit past 100% of comp)?"

"A plan has an eligibility requirement that a participant must work 6 moths with 150 hours in each month in order to become eligible for the Profit Sharing source? Eligibility computation period is defined as anniversary year for the first year and then it switches to the calendar year. We have a participant who was hired a few years ago and worked around 500 hours per year, then was terminated and re-hired multiple times over the years. We count all years after a break in service. For eligibility determination, which option is correct: [1] We determine if the employee is eligible (worked 6 months with 150 hours in each month) for each eligibility computation period. So, if the employee did not work 6 months with 150 hours from date of hire to anniversary date, we switch to calendar year and determine if she worked 6 months with 150 hours during that calendar year, etc. [2] We determine if she ever worked 6 months with 150 hours (at any point since being employed). I believe option 1 is correct since the eligibility computation period is the 12 month period. Do you agree?"

"DB plan terminated and did all the distributions during 2026 and also paid the RMD based on account balance method. Now, a small residue ($550) hit the account which is also subject to RMD. It is roughly $20. I cannot remember if there was a de minimus amount that can be ignored? Actual distribution was 2.5M with RMD of 100k."