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Guest MES

"brief exclusion" of an eligible employee from a 401(k) plan

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Guest MES

An employee is due to enter a 401(k) plan on April 1. He is excluded until May 1. From Rev. Proc. 2000-17, it appears that a QNEC must be made since the employee will not have the opportunity to defer for the last nine months of the year. However, this employee would have only been able to defer 9 months had he entered on his eligiblity date. Has anyone considered whether this 9 month rule can be pro-rated depending on the entry date which was missed? Any opinions?

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