Leaderboard

Employer contributions technically do not need to be until the due date of the business return, including extension. Therefore, I don't think you have a late remittance issue here, and you do not have an operational failure.

Hmmm - I'm not so sure about that. 1.72(p)1, Q&A-7 refer you to the "tracing rules" in 163(h)(3)(B). As I read those rules, if you can't prove that the funds were actually used in "acquiring, constructing, or substantially improving" the qualified residence, then I don't necessarily think it qualifies. So, if you buy a house for $200,000, and take a mortgage loan from the bank for $180,000, and said loan is secured by the residence, and you additionally take a $50,000 loan from your plan, and use $20,000 for the difference, and then spend the other $30,000 on a trip to Monaco, do you think this qualifies? More to the point, do you think the IRS would agree? Just curious.

Sure, but your headaches still make for interesting discussion starters for the rest of us

Relius will of course run a plan that large, though perhaps slower than a plan with fewer folks. I understood the question to be : we ran the test on a spreadsheet we know the ADP for both HCE and NHCE Plan fails, we want the refund numbers. so at this point, to reiterate, lets say you only have, say, 50 HCEs amongst the 4000 I would load the HCEs only up on Relius and run the test. (it doesn't matter if it is current or prior year testing, just plug the avg NHCE rate into prior year test field) ........... I had read the post yesterday and wondered about such a spreadsheet. then it dawned on me to approach it from a different point of you. sort of reminds me the 'story' the Americans spent millions to come up with a pen that would write in outer space. The Russians decided to use a pencil.