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Pick up contributions


Guest meggie
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Guest meggie

Is it possible to retroactively correct a situation where pick up contributions should have been withheld effective with a person's date of hire and the muncipality failed to do so? [Date of hire = 6/2002]. The town would like to correct the error and is looking for assistance. Participation in the pension plan is required as a condition of employment. Thanks.

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Guest meggie

Thanks for the reference- but I don't believe failure to withhold pick up contributions under 414(h)(2) is specifically addressed in Rev. Proc. 2002-47.

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It might not be. My concern is that the employer might have failed to follow the terms of the plan, which according to the IRS is a disqualifying event. If the employer has failed to follow the terms of the plan, that failure should be corrected under RP 2002-47, by self-correction, if self-correction is allowed (which it probably is here), or by submission to the IRS.

My point in my first post was to answer your question about whether it is possible to retroactively correct. Correction is possible, and probably also required to maintain plan qualification.

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  • 3 weeks later...

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