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Excess Deferral (402(g) Limit) Distribution Deadline


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Hello,

 

Do you know if the April 15th deadline for Distribution for Excess Deferrals (participant worked at 2 companies during the year and exceeded the Deferral Limit when we look at the total Deferrals) is now July 15th for 2020 due to COVID? It seems like it should be because that's the new tax deadline, but just wanted to make sure.

 

Thanks.

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Maybe this?

IRS Notice 2020-23:

"For an Affected Taxpayer with respect to Specified Filing and Payment Obligations, the due date for filing Specified Forms and making Specified Payments is automatically postponed to July 15, 2020.... This relief is automatic ... The Secretary of the Treasury has also determined that any person performing a time-sensitive action listed in ... Revenue Procedure 2018-58 ...  which is due to be performed on or after April 1, 2020, and before July 15, 2020 (Specified Time-Sensitive Action), is an Affected Taxpayer."

Rev. Proc. 2018-58 -- See page 48

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Most plan documents are hard-wired with an April 15 deadline to distribute excess elective deferrals. Will this extension under IRS Notice 2020-23 until July 15 override the terms of the plan document which require distribution by April 15?

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