Mid-west Forge Boilermakers 401(k) Plan

Left in 2020, 2021, 2022? Worth asking about employer money

• In plan year 2020, active participants fell from 147 to 115 (22%), and 25 people left before they were fully vested. When a plan loses about 20% or more of its participants in a year, the IRS presumes a partial plan termination (Revenue Ruling 2007-43). Everyone who left in that period must then be fully vested in the employer's contributions. A 2021 law (Consolidated Appropriations Act, section 209) can excuse a drop between March 2020 and March 2021 if the plan had rehired enough people by March 31, 2021. Filing
• In plan year 2021, 31 people (27% of active participants) left before they were fully vested. Turnover that high can count as a partial plan termination (Revenue Ruling 2007-43), which requires full vesting of employer money for those who left. The plan may argue it was routine turnover. A 2021 law (Consolidated Appropriations Act, section 209) can excuse a drop between March 2020 and March 2021 if the plan had rehired enough people by March 31, 2021. Filing
• In plan year 2022, active participants fell from 97 to 65 (33%), and 8 people left before they were fully vested. When a plan loses about 20% or more of its participants in a year, the IRS presumes a partial plan termination (Revenue Ruling 2007-43). Everyone who left in that period must then be fully vested in the employer's contributions. Filing

This is a reason to ask the plan, not a finding. The plan decides, and it may show the drop was routine.

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Check your years. We show whether the plan merged or moved money while you were there, and draft the letter to the plan that holds it now.

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