In my previous blog, “The Voluntary Fiduciary Correction Program – Overview”, I discussed the Voluntary Fiduciary Correction Program (VFCP).
By filing through the VFCP, a plan sponsor will receive a no-action letter from the EBSA indicating to the plan that the EBSA will not take civil action against the plan sponsor with regard to this specific transaction in the submission. It is also important to note that there is no application fee to file through the VFCP.
Although the Internal Revenue Code trumps IRS Publications, practitioners tend to use the Publications as the initial resource when handling day-to-day tax issues.
What Goes in the Denominator? Complying with the Allocation Rules for Distributions from Qualified Plans With After-Tax Accounts
Compliance starts with understanding. Understanding the rules set forth in Notice 2014-54, assisted us with the application of the rules in a situation in which a participant was entitled to take a distribution from his after-tax account only, in a qualified plan that provides and separately accounts for:
Lack of clarity causes frustration. The topic of how to properly allocate the pretax and after-tax amounts attributable to distributions from qualified plan accounts that include Roth 401(a) accounts or after-tax accounts has been a source of much debate in the retirement plan community.