jpokusa
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So, are you saying there would be no excise tax?
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If an employer fails to deposit a top heavy minimum contribution for a prior year, should form 5330 be filed and an excise tax paid. If so, it appears it would be shown as a prohibited transaction similar to late deposit of employee deferrals rather than a late required employer contribution under minimum funding standards.
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Thanks, Hadn't thought about that.
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One of our clients has a 401(k) plan. During 2017, the employer created 2 new controlled group companies. All of the employees then became employees of one of the new companies. We were never informed of this and the 2 new companies were never added to the plan as participating employers. They continued to deposit deferrals for the employees. Do the deferrals have to be refunded? Or can this be corrected under EPCRS? Any other suggestions?
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Would he be included in the 401(a)(4) test for a new comp plan?
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If a company adopts a 401(k) plan midyear retroactively to the beginning of the year and an employee met the eligibility requirements at the beginning of the year, but terminates employment prior to the adoption date, must he be included in the 401(a)(4) testing? Must he receive the 3% non-elective safe harbor contribution?
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The plan has the compensation limit increases built it, so it looks like they can recognize the higher comp limit in benefit calculations. Thanks.
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Is the increase in the 401(a)(17) compensation limit considered to be a plan amendment increasing benefits as restricted by 436 for an underfunded DB plan and therefore cannot be used to calculate benefits, or is it only considered as such an amendment as applied to the 415 limit?
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We have a non-ERISA 403(b) plan that wants to add a match. We would like to add a 4% enhanced safe harbor match, thereby making it subject to ERISA. The question is, can this be done mid-year?
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Refund it as an excess contribution.
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Should an employee who has not met the eligibility requirements who is allowed to defer be included on line 5c?