Plan sponsors should check their calendars and be aware that the deadline for making corrective distributions to HCEs (without an excise tax penalty) for a failed ADP or ACP test is quickly approaching. – General deadline is within 2 ½ months after end of plan year (i.e., March 15th for calendar year plans). – The [...]
The DOL recently announced an extension of the deadline for service providers to comply with Section 408(b)(2) regulations. These rules govern the disclosure of fees charged to qualified retirement plans (e.g., 401(k) and defined benefit pension plans). Disclosures were originally required by July 16, 2011, which has now been extended to January 1, 2012. The [...]
Now that many plan sponsors have completed their 2009 Form 5500 filings for their retirement and welfare plans, they may be wondering about the status of the proposed online posting of these filings. We hadn’t heard much about this requirement lately, but buried in the new proposed DOL Annual Funding Notice regulations is a reference [...]
The IRS just published the retirement plan limits for 2011. Most of the limits for retirement plans are unchanged – again. They’re the same as 2009 and 2010: Maximum annual pension plan benefit $195,000 Maximum annual addition for defined contribution plans 49,000 Maximum 401(k) elective deferral 16,500 Maximum catchup contribution (age 50 and over) 5,500 [...]
Despite the DOL’s rejection of a previous request by the American Benefit Council for automatic extension of time to file the 2009 Form 5500 until December 31, 2010, the American Society of Pension Professionals and Actuaries (ASPPA) has filed a similar request with the DOL and IRS. With less than two weeks until the filing [...]
The Small Business Jobs Act of 2010 (H.R. 5297) passed the Senate last week and is expected to be signed into law by the President. As we mentioned in a previous post, there are a couple of retirement plan changes included in this bill. They include: – Add a Roth option for 457(b) plans. This [...]
Employers (large and small) will want to be aware of a provision included in a Senate jobs bill last week: the potential to allow eligible rollovers from a traditional 401(k) plan into a Roth 401(k) plan. Business Insurance has a good summary of some of the details, and here are some of the highlights: The [...]
A while back I read a blog post titled “The Beer Napkin Annuity” (BNA) that I found intriguing (if nothing else, the name is catchy). The basic premise was that perhaps we could adjust our retirement tax deduction rules to transfer some deduction opportunities traditionally reserved for defined benefit (DB) plans to defined contribution (DC) [...]
It was a bit of a longshot to begin with, but the American Benefits Council’s proposal for a blanket extension for filing of 2009 Forms 5500 until December 31, 2010 (or 9 1/2 months after the end of the plan year, if later) was recently rejected by the DOL. As the DOL mentions in their [...]
Our philosophy for coverage and nondiscrimination testing has always been “everything passes, some plans just take a little longer to prove it”. That was put to the test recently for one of our law firm clients: an unusually young new partner was causing their §401(a)(4) nondiscrimination test to fail. We emptied the whole toolbox on [...]
