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Failed ADP test deadline and plan merger


cpc0506

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We have a client with plan year ending 6/30.  We completed valuation work for plan year ending June 30, 2017.  At that time the plan, called Plan A,  both failed the ADP Test and the plan’s assets were merged with another plan, called Plan B,  so that the ending balance on the 2016 Form 5500 for Plan A was reported as  zero and a final return was filed.   Assets merged into Plan B as of 6/30/17. Plan B has a plan year ending 12/31.   

My question has to do with the deadline for returning ADP failures before a one to one QNEC is required. Is the based on old Plan A’s  plan year end or new Plan B’s plan year end?  And if it is based on new Plan’s plan year end, was the deadline 12/31/17 or does it extend to 12/31/18?  In order words, what was/is the final date for making refunds under this scenario?

 

 

 

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