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Hi Benefits Link contributors - Hoping someone can help by lending their opinion. Plan terminates on March 31, 2016. Salary deferrals stopped on March 31, 2016. Distributions will not get completed until September so technically the plan year will end on 9/30/2016, not 3/31/2016. Note that 1.401(a)(17) -1 (b)(3)(iii) on "Compensation for a period of less than 12 moths states...(iii) ......"In addition, if the period for determining compensation used in calculating an employee's allocation or accrual for a plan year is a short plan year (i.e., shorter than 12 months), the annual compensation limit is an amount equal to the otherwise applicable annual compensation limit multiplied by a fraction, the numerator of which is the number of months in the short plan year, and the denominator of which is 12. Does logic trump or the literal reading? Another words, can I use $198,750 in the ADP test for 2016 based on the plan year ending 9/30/2016, or is the plan year deemed ended when the plan terminated so $66,250? Thanks, Craig Schiller
