MrsMacias Posted May 2, 2022 Share Posted May 2, 2022 A client provided a revised census for 2020 testing. When 2020 testing was rerun it was determined that the plan failed less than the original test. Corrective distributions had already been paid out and reported for 2021 taxes by the time the revised test was run. Participants are no longer able to return the excess corrective distributions to the plan. What is the correction? We are thinking that the client needs to submit the difference back to the plan but not the participant accounts. Is this correct? Link to comment Share on other sites More sharing options...
Bri Posted May 2, 2022 Share Posted May 2, 2022 Why can't they return the excess? Link to comment Share on other sites More sharing options...
MrsMacias Posted May 2, 2022 Author Share Posted May 2, 2022 They are legally able to however, the participants no longer have the funds to return. Link to comment Share on other sites More sharing options...
Bri Posted May 4, 2022 Share Posted May 4, 2022 Ooh! Is there profit sharing? How about doing a QNEC to some HCEs in order to cause the actually-refunded amounts to be correct after all and see if you still pass 401a4? (I'm not feeling well today. Sorry.) Link to comment Share on other sites More sharing options...
BG5150 Posted May 9, 2022 Share Posted May 9, 2022 Too late to do a QNEC, I think. QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left. Link to comment Share on other sites More sharing options...
Bri Posted May 13, 2022 Share Posted May 13, 2022 ooh, right, sorry - misread the year in question. (Was dealing with reaction from booster shot) Link to comment Share on other sites More sharing options...
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