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Minna Nah

About Minna Nah

Minna coordinates Sense Financial's communication efforts towards educating clients about the Self Directed IRA and Solo 401k. She enjoys the opportunity to work with clients from various backgrounds, experiences, and goals. She strives to ensure that each client’s goals are met through the products Sense Financial offers.

Posts by Minna Nah:

Your role as Solo 401k fiduciary

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Did you know that you are the fiduciary of your Solo 401k?

In addition to being a participant in the plan, administering the plan as plan administrator, directing the plan as trustee, you are also the fiduciary.

This means that you are responsible for doing the following, as noted by the US Department of Labor (DOL):

  • Acting solely in the interest of the participants and their beneficiaries;
  • Acting for the exclusive purpose of providing benefits to workers participating in the plan and their beneficiaries;
  • Paying only reasonable plan expenses;
  • Carrying out duties with the care, skill, prudence, and diligence of a prudent person familiar with such matters;
  • Following the plan documents; and
  • Diversifying plan investments

With the benefits of your Solo 401k comes responsibilities. To equip yourself for your fiduciary responsibilities, do the following:

Read your plan documents

Review the set of plan documents that was sent to you by Sense Financial.

The Defined Contribution Adoption Agreement is the central document of your set. Take a few minutes to read through it.

The Summary Plan Description takes the selections from the Defined Contribution Adoption Agreement and spells them out in plain language, in a question and answer format.

Read and watch the resources on the client portal

The client portal is your go-to resource, available at all times.

The Knowledge Base is a great section to read, look up topics via search, and learn. Our videos are also available in the Education section of the client portal.

Make sure you are subscribed to Sense Financial's emails

Most importantly, our compliance emails. We regularly send out announcements, reminders, and updates related to keeping your plan in compliance.

List quoted from the US Department of Labor (DOL) resource below:

https://www.dol.gov/sites/dolgov/files/ebsa/about-ebsa/our-activities/resource-center/publications/automatic-enrollment-401k-plans-for-small-businesses.pdf

Mega backdoor Roth within the Solo 401k

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What it is

The mega backdoor Roth strategy is a way to get more Roth funds into your retirement account. Roth funds are taxed initially but grow tax-free.

The mega backdoor Roth strategy consists of:

  • Making after-tax contributions to the Solo 401k, and
  • Converting those after-tax contributions to Roth within the Solo 401k, and
  • Keeping those Roth funds in the Solo 401k for checkbook-control investing or rolling over the funds into a Roth IRA

The Mega Backdoor Roth strategy offers an alternative to contributing to a Roth IRA directly, which is limited to $7,000 per year by the IRS. Many individuals also do not qualify for a Roth IRA due to their high earnings.   

Your Solo 401k with Sense Financial already includes the features which allow you to utilize the mega backdoor Roth strategy.

How it works

  • Open separate accounts for your Solo 401k to house your after-tax contributions and Roth funds, if you do not have these already

From a banking standpoint, these separate accounts will be identical. Both are in the name of your 401k and using the EIN of your 401k. However, these accounts are established to keep the funds separate from each other and to assist you in your accounting of each type of fund within your 401k. You can assign nicknames to the separate accounts online in order to differentiate them.

  • Calculate the after-tax contribution based on your self-employment business earnings
  • Make the after-tax contribution into the 401k account for after-tax contributions
  • Once that after-tax contribution is in your 401k, immediately convert the funds to Roth and move those funds to the Roth account

Note that the growth on the after-tax contribution is taxable, so you will want to convert the after-tax contribution to Roth immediately after the contribution is made.

  • Keep those funds within the Roth account of your Solo 401k for checkbook-control investing or roll those funds over to a Roth IRA
  • The following year, file a 1099-R to document the conversion

How it should be reflected on a 1099-R

In this case, the 1099-R should document the conversion of the after-tax contribution to Roth within your 401k. The Payer is your 401k trust, which is issuing the 1099-R to you, the Recipient.

  • Payer: your 401k trust
  • Payer TIN: the EIN of your 401k trust (not the EIN of your adopting business)
  • Recipient TIN: your SSN
  • Recipient: you, as an individual
  • Box 1: Gross distribution: amount that was converted to Roth
  • Box 2a: Taxable amount: 0.00 if the after-tax funds were converted to Roth immediately. The taxable amount would be 0.00 since the after-tax contribution was not originally claimed as a deduction and was converted to Roth immediately. If the after-tax contribution was not converted to Roth immediately, the growth amount is taxable and should be entered here.
  • Box 5: Employee contributions/Designated Roth contributions or insurance premiums: amount of the original after-tax contribution. If you converted the after-tax contribution to Roth immediately after making the contribution, this should be the same amount as in Box 1
  • Box 7: Distribution code: G which indicates a direct rollover (from after-tax to Roth) within the plan, your 401k

When the 1099-R should be filed

The 1099-R is filed in the year following the year in which the Roth conversion was performed (e.g. the 1099-R for 2022 is filed in 2023). There are two deadlines for the 1099-R:

  • The Payee/recipient copy must be received by January 31st
  • The electronic copy must be filed with the IRS by March 31st

You are responsible for the filing of the 1099-R by both deadlines.

Sense Financial can assist with the filing of the 1099-R by request only, provided that we receive your request by our deadline of the second Monday in January.

After-tax contributions

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The Solo 401k allows you to contribute to your plan in two ways- as employee and employer. Within the category of employee contribution, there are three types:

  • Pre-tax
  • Roth
  • Voluntary After-tax

Defining the three types of employee contributions

  • A pre-tax employee contribution is taken from compensation earned and reduces the taxable income. If you made a pre-tax employee contribution, you would deduct the amount of that contribution on your tax return.
  • A Roth employee contribution is taken from compensation earned and does not reduce the taxable income. If you made a Roth employee contribution, you would pay taxes at the time of the contribution.
  • A voluntary after-tax employee contribution is taken from compensation earned and does not reduce the taxable income. If you made a voluntary after-tax employee contribution, you would pay taxes at the time of the contribution.

What are the differences between them?

There are two main differences between these three types of employee contributions- how the distribution is taxed and the maximum limit of the contribution.

  • How the distribution is taxed

When a pre-tax employee contribution is distributed, both the principal amount of the contribution and its growth is taxed at the current rate at the time of distribution.

A Roth employee contribution and an after-tax contribution is a qualified distribution when you are age 59.5 and older and the funds have been in the 401k for 5 years or longer.

With both a Roth employee contribution and an after-tax contribution, the principal contribution amount is not taxed upon distribution. However, the two contributions differ in whether the growth is taxed.

When a Roth employee contribution is distributed, both the principal contribution amount and the growth are distributed tax-free.

When an after-tax employee contribution is distributed, only the principal contribution amount is distributed tax-free. The growth is taxable and must be taxed at the current rate at the time of distribution.

  • Maximum limit of the contribution(s)

Both a pre-tax and a Roth employee contribution is subject to a combined maximum limit:  $23,000 plus $7,500 catchup (for those age 50 and above) for 2024. In other words, you can make pre-tax contributions, Roth contributions, or a combination of both, but the combined total cannot exceed the maximum limit for the year.

An after-tax employee contribution is subject to a different maximum limit:  $69,000 for 2024.

Making an after-tax contribution

Your Solo 401k plan now includes the ability to make after-tax contributions.  All three types of employee contributions are documented in the Post PPA version of your Adoption Agreement.

If making an after-tax contribution, you will first want to establish a separate account for the contribution(s).  Because an after-tax contribution is different from a Roth contribution, the after-tax contribution should not be kept in the same account as a Roth contribution.

Once the after-tax contribution is made to its own account, the funds can then be converted to Roth within your 401k as part of a mega backdoor Roth strategy. Due to the tax consequences of the mega backdoor Roth strategy, you will want to check with your CPA first before undertaking the strategy.

Reporting CARES Act distributions and repayments

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The IRS has released Form 8915-E and 8915-F for the reporting of CARES Act distribution(s) that were taken in 2020, their repayment, or their inclusion in income.

If you took a CARES Act distribution in 2020, note which form(s) would apply to you:

Form 8915-E is used to report:

  • If you took a CARES Act distribution in 2020

Form 8915-F is used to report:

  • Your income in 2021 if you took a CARES Act distribution in 2020 and have been including in your income in equal amounts over 3 years and that 3-year period has not yet lapsed
  • Your repayments of a CARES Act distribution, if repaying the distribution

Note that repayment of the CARES Act distribution can be done over 3 years, starting with the day after the distribution was received. Repayment(s) can occur through multiple payments or one lump sum payment by the end of those 3 years. If the entire CARES Act distribution is paid back within that time, the distribution will not be taxed.

You will want to request your CPA’s assistance in completing the appropriate form for your situation. 

More information on these two forms can also be found at:

https://www.irs.gov/forms-pubs/about-form-8915-e

https://www.irs.gov/forms-pubs/about-form-8915-f-qualified-disaster-retirement-plan-distributions-and-repayments

Contribution basics

As the year comes to a close, we'd like to remind you to plan for your contributions to your Solo 401k. In this article, we'll discuss the following questions:

  1. How do I calculate my contributions for this year?
  2. How do I actually make contributions to my Solo 401k?
  3. When is the deadline to make contributions?

How do I calculate my contributions for this year?

  • Solo 401k contributions are comprised of two components:
    • On the employee side – employee salary elective deferral
    • On the employer or business-owner side – employer profit sharing
  • Contributions can only be made from the business earnings of the adopting business
  • The Contributions Calculator explains the maximum employee and employer contributions that can be made to the Solo 401k
  • Always check the totals with your CPA.

For more information:

How do I actually make contributions to my Solo 401k?

  • The way to make contributions to your Solo 401k depends on the type of adopting business.
  • If your Solo 401k is sponsored by a corporation:
    • Employee salary elective deferrals must be processed through payroll. Speak with your payroll provider to request this.
    • If payroll has already been processed for the year, the only option is to amend the Q4 reports to reflect the contributions to the 401k. Keep in mind that contributions will affect the taxes paid as well as other numbers.  Speak with your payroll provider about making this correction.
  • If your Solo 401k is sponsored by another type of business (e.g. sole proprietorship, LLC), all contributions must come from your adopting business's bank account.
  • All contributions must be elected and documented via the appropriate form.
  • There are two forms, depending on the type of contribution made.
  • All elections to contribute must be made before December 31st of the year. This means the date on your contributions form must be before December 31st.
  • As Plan Administrator, keep the completed contribution forms as part of your record-keeping for the plan.
  • Issue a check payable to your 401k trust (refer to the IRS letter for the exact spelling)

For more information:

When is the deadline to make contributions?

  • The Solo 401k contribution deadline can vary depending on two factors:
    • Type of adopting business (e.g. sole proprietorship, single-member or multiple-member LLC, C or S Corporation)
    • How the contribution is made, e.g. as an employee salary elective deferral or employer profit-sharing
  • Review our “Contribution Deadline” article for the specific deadlines

For more information:

Filling out a W-9 for the Solo 401k Trust

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The bank sent me a Form W9 to fill out for my Solo 401k Trust.  How do I fill it out?

Answer:

Fill out form as follows:

  • 1 - Fill in the name of your Solo 401k Trust (refer to IRS letter for the exact spelling)
  • 2 - Leave blank
  • 3 - Check "Other"  and fill in "401k Retirement Trust"
  • 4 - Enter code "1" for "Exempt payee code"
  • 5 and 6 - Enter your address as the Solo 401k Trustee
  • Part I - Enter the EIN for your Solo 401k Trust (refer to IRS letter)
  • Part II - Sign and date

Filing Form 5500-EZ if the value goes down

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If I file Form 5500-EZ now, does that obligate me to file subsequent 5500-EZ forms for the following years even if the total plan assets are below 250k?

Answer:

No.  Form 5500-EZ is required only if the total value of the 401k plan is $250,000 or above by the end of year.

Filing the 5500-EZ is not required if the total plan assets are below $250,000 by the end of the year, even if the form has been filed for the previous year.

As noted in the IRS instructions for Form 5500-EZ:

You do not have to file Form 5500-EZ for the 2016 plan year for a one-participant plan if the total of the plan's assets and the assets of all other one-participant plans maintained by the employer at the end of the 2016 plan year does not exceed $250,000, unless 2016 is the final plan year of the plan.

Can profit sharing contributions be made to my Solo 401k throughout the year?

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Can profit sharing contributions to my Solo 401k be made throughout the year, or do I have to wait until the end of the year to make them?

Answer:

Profit sharing contributions can be made throughout the year. However, note that the profit sharing contributions are limited to a percentage of your compensation (25% for corporations, 20% for single member LLCs or sole proprietors) at the time you are making them.

 

For example, if your compensation (i.e. the wages you take from the company) up to date are $16,000, your corporation can put up to $4,000 in profit sharing contributions.

How do I terminate my Solo 401k plan?

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ANSWER:

Terminating your Solo 401k plan includes the following steps:

  • Distribute all assets of your Solo 401k plan

Distributions may be taxable or non-taxable, depending on the type of distribution taken. 

  • Formally request to terminate your Solo 401k plan

You must submit a request to us in writing for the termination of your Solo 401k plan.

  • We will issue a Plan Termination package to you

The plan termination package includes two documents which will be emailed to you- the Action by Board of Directors document and the Plan Termination package.

  • Sign the documents and keep them for your records

Since you are Plan Administrator, you are responsible for keeping all records related to the Solo 401k plan.  This includes the termination documents.

  • Prepare the filing for the year in which the Solo 401k plan was terminated

If you are terminating your Solo 401k Plan this year, you will have to complete the following forms next year.  Obtaining, completing, and submitting these forms are your responsibility.

  1. A 1099-R is required for both taxable distributions and non-taxable rollovers.  This form must be distributed to the recipient of the distribution in January of the year following the distribution or rollover.
  2. A final 5500-EZ is required for all terminated 401k plans

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