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Should we amend 5500 or make QNEC


pam@bbm

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We have a 401k plan with employer contributions of safe harbor non-elective and additional profit sharing. The plan has a November 30 year end. While completing the 11/30/2015 year end administration, it was discovered that the employer failed to provide census information for 2 employees for the prior year of 11/30/2014. Both employees had met eligibility to enter the plan during the 11/30/2014 plan year and should have received employer contributions.

We are calculating a QNEC for the missed deferral opportunity. But for the missed employer contributions, should we amend the 11/30/2014 year's 5500 or compute a QNEC to be included in the 11/30/2015 5500?.

Thank you for your thoughts.

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