Client withdrew funds from IRA, intending to redeposit that amount within 60 days and avoid the tax. She is not going to be able to meet the 60-day deadline. Can she withdraw an additional amount, then turn around and deposit it back into the IRA to cover the first withdrawal within the first 60-day period, starting a new 60-day clock on the second withdrawal? She thinks she will have the funds to cover it before the end of the second 60-day period.

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Proverbial takeover case. Loan should have defaulted in 2006 at around $46,000. Some payments have been made since then but not many, and even those have been sporadic. At 8.25%, John Hancock is carrying this at $75,000 now. I'm referring this to an attorney, but just curious what BL mavens have to say as likely outcomes under VCP, or other thoughts.

I'm skimming the regulations about whether offering different vesting schedules to different groups of employees would need to be tested for benefits rights and features. What I'm reading is that vesting schedules would not need to be tested for BRF. Is this correct? For example offering immediate vesting to HCEs but 6 year graded for NHCEs on the same allocation:

(ii) Exceptions to definition of other right or feature. Notwithstanding paragraph (e)(3)(i) of this section, a right or feature is not considered an other right or feature if it

(A) Is an optional form of benefit or an ancillary benefit under the plan;

(B) Is one of the terms that are taken into account in determining whether separate optional forms of benefit or ancillary benefits exist, or that would be taken into account but for paragraph (e)(1)(ii) of this section (e.g., benefit formulas or the manner in which benefits vest ); or [remainder omitted]

In considering whether tax legislation has a realistic possibility in the lame-duck remainder of the current Congress, do we know whether Congress can use budget reconciliation to act on a simple-majority vote? Or is once-a-year reconciliation used up (so that action in the Senate would require the cloture-granting supermajority)?

A state government offers a Section 125 cafeteria plan to state employees. However, I have the same question even if it's a private employer. A sales person from another company is approaching the state/employer, saying that his company can offer a second plan that will supplement or compliment the first plan. I'm very leery of promises that seem to be too good to be true from sales people. Can the state/employer tack on another plan without running into trouble? Even the logistics of trying to operate 2 plans seems confusing.

Where a trust/trustee is located in one state, but the plan and its beneficiaries and the unrelated business are located in another state, what state law applies when considering taxation of UBIT?

My question is about the alternative wellness credit rule and how that impacts biometric screenings in remote work locations. We would like to use a national Lab to do our Biometric Screenings. Unfortunately, some of our job locations do not have a national retail lab nearby them. The national lab could send electronic interfaces that would allow wellness credits to be provided to employees without using to much of the benefit department staff. Are we required to provide an alternative solution for biometric screenings for remote work sites that would not have a national lab near them or could those employees be excluded, unless they are willing to drive several hours to a lab retail location, to avoid manual payroll credit entries. In other words, possibly avoiding giving credits for each employee doctors lab work with manual upload files for small town remote locations. At some point we would like to maybe do mail order kits, but not right now.

Is a health plan administrator allowed to retroactively change already-paid COBRA premiums (and without notice)? My former employer's health plan has a plan year that runs September 1 through August 31. Premiums had been $1,000 per the coupons/notice provided to me. Faithfully paid for the past year (Sept. 1, 2017 through Aug. 31, 2018). Everything is fine, insurance is fine. New COBRA premiums are noted for September 2018 going forward, say $1,500. But can they/administrator also change the past premiums? That is, they now, along with new forward rates, say COBRA premiums for past "2017 Sep -- Aug 2018" are being changed to $1,100 (without notice, just changed history in online billing). And then they want either (a) top-up payment for the past year, or (b) to reassign my past payments and claim that I was thus short a few months ago so as to cancel my health insurance retroactive to that date. Yes, this happened to me. A pointer to any relevant official documents/paragraphs on this is very much appreciated.

Owner of the company passed away at age 85. Money was in pooled account and funds are requesting be disbursed to his charitable trust per beneficiary form. Does the pooled account have to be revalued to date of death?)It's audited plan with 250 employees and multiple brokerage accounts.) How is the RMD handled before the disbursement to the charitable trust?