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415 Annual Additions


Guest KDGCRK
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Guest KDGCRK

I represent a local government that sponsors a defined contribution plan. The plan calls for the local government to contribute a specified portion of the employees' salary to the plan. In some years the local government did not contribute the proper amount, it under-contributed by several percent.

We are in the process of submitting a VCP Application to correct 415 and 401(a)(17) violations as to certain participants. We would like to add this "under-contribution" problem to the Application. Our proposed correction method is to have the government "make up" the undercontributed amounts by making a "make up" contribution in the amount which was under-contributed.

The question is whether these "make up contributions" will be treated as annual additions in the year they are made or if they can relate back to the year of the undercontribution for purposes of 415.

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I think you'll probably need to have the make-up include an interest component, too. But the contribution sounds to me like it be related to the prior year. I think this is one of the benefits you get from filing the application with the IRS.

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