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DLMRetire

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  1. Participant elects to defer 3% of pay in 2015 and employer doesn't implement election fro 10 months. 3% of pay equals $10,000. Employer does applicable notice to employee and deposits $2500 per 2015-28. No match. Questions: Can employee defer add'l $15,500 ($18,000 less $2500) or are they limited to $8000 (18000-10000). IRS Webinar from a while back seems to say 402g limit is reduced by missed deferrals so i'm thinking participant limited to $8000 but cant find anything really concrete on this. Also, does the $2500 count as employer contribution in general test. I think not, but again, cant find anything concrete on this.
  2. It is not yet set up so question somewhat of a hypothetical. So if we had one plan adopted by each member of controlled group but one employer matches and other does not (ie document written so each employer has discretionary match each year) and we define compensation as paid by employer (meaning both employers) can we limit match each pay period to only comp and deferrals paid by respective employer who is making such match? Definately understand there could be 414s testing and nondiscrim testing issues.
  3. Controlled Group consisting of 2 entities. One entity "M" declares a match , the other entity "NM" does not for a particular year. If employee A earns wages from "M" and "NM" and defers off of wages from both "M" and "NM", do we need to use deferrals and wages from "NM" when figuring out the amount of match "M" owes? Is it possible to word each document to exclude such wages and deferrals from the other entity when calculating the match? Understand that combined testing ADP/ACP required.
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