Mistake #11

November 2017 Mistake: The plan was top-heavy and required minimum contributions weren’t made to the plan. Fix the Mistake: Properly contribute and allocate the required top-heavy minimum, adjusted for earnings, to the affected non-key employees. Monthly BBQ Recipe  Monthly Beverage Recipe Sazerac Ingredients 1 teaspoon sugar 3 or 4 dashes Peychaud’s Bitters A few drops of water 2 ounces (60ml) rye whisky, such as Sazerac Rye 1 teaspoon Herbsaint, Pernod, pastis, or absinthe 1 lemon peel Directions Chill an Old Fashioned glass or small tumbler in your freezer. In a mixing glass, combine sugar, Peychaud’s Bitters, and [...]

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Mistake #10

October 2017 Mistake: Hardship distributions weren’t made properly. Fix the Mistake: Amend plan retroactively to allow for hardship distributions. If impermissible hardship distribution, have participant return hardship distribution amount plus earnings. Monthly BBQ Recipe  Monthly Beverage Recipe Tom Collins Ingredients 2 ounces (60ml) gin Juice of 1/2 a lemon 1 teaspoon sugar (preferably superfine) Chilled club soda Directions Add gin, lemon and sugar to a Collins glass and stir to dissolve sugar (you can instead use simple syrup and make the process easier). Fill glass with large chunks of ice and top with chilled [...]

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Mistake #9

September 2017 Mistake: Participant loans don’t conform to the requirements of the plan document and IRC Section 72(p). Fix the Mistake: You may correct some failures by corrective repayment and/or modification of loan terms. Monthly BBQ Recipe  Monthly Beverage Recipe Pisco Sour Ingredients 3 ounces (90ml) pisco 1 ounce (30ml) fresh=squeezed lime juice 3/4 ounce simple syrup (see note*) 1 fresh egg white 1 dash Angostura or Amargo bitters Directions Combine pisco, lime, simple syrup, and egg white in a cocktail shaker without ice ans seal. Shake vigorously until egg white is foamy; about 10 seconds. [...]

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Mistake #8

August 2017 Mistake: You haven’t timely deposited employee elective deferrals. Fix the Mistake: Usually corrected through DOL’s Voluntary Fiduciary Correction Program. You may also need to correct through the IRA correction program. Deposit all elective deferrals withheld and earnings resulting from the late deposit into the plan’s trust. Monthly BBQ Recipe  Monthly Beverage Recipe Daiquiri Ingredients 1 ounces (60ml) light rum (you can also use gold rum, but dark rum can be too heavy). 3/4 ounce fresh-squeezed lime juice (about 1/2 of a lime) 2 teaspoon sugar Directions Pour sugar and lime juice into a [...]

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Mistake #7

July 2017 Mistake: You didn’t base the plan operations on the terms of the plan document. Failure to follow plan terms is a very common mistake. Fix the Mistake: Apply reasonable correction method that would place affected participants in the position they would’ve been in if there were no operational plan defects. Monthly BBQ Recipe  Monthly Beverage Recipe French 75 Ingredients 1 ounce (30ml) gin 1/2 ounce (15ml) freshly squeezed lemon juice 2 teaspoons sugar 2 ounces (60ml) champagne or sparkling wine Garnish: long thin lemon spiral and cocktail cherry Directions Fill cocktail shaker [...]

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Mistake #6

June 2017 Mistake: Eligible employees weren’t given the opportunity to make an elective deferral (exclusion of eligible employees). Fix the Mistake: Make qualified non-elective contributions for the non-highly compensated employees. Monthly BBQ Recipe  Monthly Beverage Recipe Side Car Ingredients 2 ounces (60ml) VSOP Cognac, Armagnac, or good California brandy 1 ounce (30ml) Cointreau 3/4 ounce fresh lemon juice, to taste Superfine sugar and lemon wedge, for garnish (optional) Directions Wet rim with lemon wedge and dip in sugar. Pour all ingredients into a cocktail shaker filled with ice. Shake well and strain into cocktail glass.

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Mistake #5

May 2017 Mistake: The plan failed the 401(k) ADP and ACP nondiscrimination tests. Fix the Mistake: Make qualified non-elective contributions for the non-highly compensated employees. Monthly BBQ Recipe  Monthly Beverage Recipe Martini Ingredients 2 ounces (60ml) dry gin 1 ounce (30ml) dry vermouth 1 dash orange bitters (optional, but highly recommended) Directions Combine ingredients in a mixing glass and fill with ice. Stir well to chill and strain into a chilled. cocktail glass. Twist a piece of lemon peel over the drink and use as garnish, or if you must, toss in an olive.

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Mistake #4

April 2017 Mistake: Employer matching contributions weren’t made to all appropriate employees. Fix the Mistake: Apply a reasonable correction method that would put affected participants in the same position they would’ve been in if there were no operational defects. Monthly BBQ Recipe  Monthly Beverage Recipe Boulevardier Ingredients 1 ounce (30ml) bourbon or rye whiskey 1 ounce (30ml) Campari 1 ounce (30ml) sweet vermouth Garnish: orange twist or cherry Directions Pour ingredients into a mixing glass and fill with cracked ice. Stir well for 20 seconds and strain into a chilled cocktail glass. Garnish with a [...]

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Mistake #3

March 2017 Mistake: You didn’t use the plan definition of compensation correctly for all deferrals and allocations. Fix the Mistake: Corrective contribution or distribution. Monthly BBQ Recipe  Monthly Beverage Recipe Brooklyn Ingredients 2 ounces (60ml) rye or other whiskey 1 ounce (30ml) dry vermouth 1/4 ounce maraschino liqueur 1/4 ounce Amer Picon, or a few dashes or angostura or orange bitters Directions Combine ingredients with ice and stir until well-chilled. Strain into a chilled cocktail glass.

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Mistake #2

February 2017 Mistake: You didn’t base the plan operations on the terms of the plan document. Failure to follow plan terms is a very common mistake. Fix the Mistake: Apply reasonable correction method that would place affected participants in the position they would’ve been in if there were no operational plan defects. Monthly BBQ Recipe  Monthly Beverage Recipe Manhattan Ingredients 1 teaspoon (5g) superfine sugar (or 1 sugar cube) 2-3 dashes bitters (Angostura is traditional and works well, Fee Brothers’ Whiskey Barrel-Aged Old Fashioned Bitters are better) 2 ounces (60ml) bourbon or [...]

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