Jump to content

402(g) Excess with Off-Calendar Year Plan


Rose

Recommended Posts

We have a plan with a plan year of 4/1/2019 - 3/31/2020.  One HCE exceeded the 402(g) limit for 2019 and we processed a refund for him (he is not catchup eligible yet).  In a calendar year plan, the excess for the HCE would be included in the ADP test since it is the year of deferral.  What happens with the off-calendar year plans? Do you just ignore the excess for ADP testing since the testing is for the plan year ending in 2020 and not the year of deferral (2019)? 

Link to comment
Share on other sites

If he's an HCE it goes in the ADP test, if he's an NHCE it is excluded from the ADP test. If that HCE requires ADP refund, you don't double refund the 402(g) and Excess deferral, that is the excess deferral that needs to be refunded is reduced by the amount already refunded becuse of 402(g). There is nothing magical about off calendar plans, just a bit more complicated figuring them out some times.

Link to comment
Share on other sites

Create an account or sign in to comment

You need to be a member in order to leave a comment

Create an account

Sign up for a new account in our community. It's easy!

Register a new account

Sign in

Already have an account? Sign in here.

Sign In Now
×
×
  • Create New...