Guest ksumner Posted September 8, 1999 Report Share Posted September 8, 1999 Let me first say that this is not a church plan. However, we are finding that the rules that apply to clergy are a bit different than the norm and it seems that this is the best place to pose a question. We have an MPP and a 401(k) plan for a client. Most of the participants are clergy (there are also some secretaries). The participants are deferring and receiving MPP contributions based on their W-2 comp plus their housing allowance. It is the only pay that they are providing us (the TPA). When we told them they were failing ADP, they insisted that the housing allowance is not includible for testing. (Please note that one participant had W-2 comp of $45,000 and a housing allowance of $36,000, making the total compensation $81,000.) Revenue Ruling 73-258 seems to back this up. However, it is very old and pre-dates 415. Here are my questions: 1)Can the clergy defer and receive benefits on the housing allowance portion of their compensation? 2) Do we include the housing allowance in ADP testing? 3) Do we include the housing allowance in 415 and 404 testing? Link to comment Share on other sites More sharing options...
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