"I'm sure most of us will recall that the IRS revamped the Form W-4P a few years ago, and the new form became mandatory for folks filing a new or updated withholding form beginning in 2023. However, it is clear that participants who began receiving payments in 2022 and earlier are not required to make an updated election. It is my understanding is that, for such a participant, the plan can continue to honor the withholding elections made on a validly submitted prior version of W-4P (unless and until the participant updates their elections using the new form). I assume this incomes flat-dollar only withholding elections. Do you folks agree or disagree? We have a client whose new systems vendor is telling them they cannot continue to honor pre-2023 flat dollar elections."

"Plan merged with another plan on 4/1/2026. How do we report on the 2026 Form 8955-SSA participants who terminated in 2025 whose benefits are being transferred to another plan -- code A and C on the same Form? One option is to inform the ongoing plan to report those individuals as an A. Looking for suggestions."

"A Solo 401(k) guy reached out to me. He deferred $4100 too much. He is pulling it out with earnings by 4/15. Does he get a 2025 1099-R for the return of the deferral or is one prepared for 2026 because it was take out in 2026? (hmmm.... did I just answer my own question?)"

"The Applicable DOL Reg:

"(1) General rule. For purposes of subtitle A and parts 1 and 4 of subtitle B of title I of ERISA and section 4975 of the Internal Revenue Code only (but without any implication for and may not be relied upon to bar criminal prosecutions under 18 U.S.C. 664), the assets of the plan include amounts (other than union dues) that a participant or beneficiary pays to an employer, or amounts that a participant has withheld from his wages by an employer, for contribution or repayment of a participant loan to the plan, as of the earliest date on which such contributions or repayments can reasonably be segregated from the employer's general assets.

"Partners ARE the employer so they have no wages. You can't withhold something from yourself. So pretty clear that they are not subject to this. My question is this: Why can't I find anything that says this, like a DOL Notice or an IRS FAQ or an article by a big law firm? Does anyone have anything to point to? I know the reg is pretty clear but this can't be the first time the topic has come up as an interesting question."