Rose Posted December 16, 2020 Share Posted December 16, 2020 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 More sharing options...
Lou S. Posted December 16, 2020 Share Posted December 16, 2020 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. Luke Bailey 1 Link to comment Share on other sites More sharing options...
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