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Showing results for tags 'one-to-one'.
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Under Revenue Procedure 2013-12, in Appendix B, Section 2.01(1)(b)(iv)(B)(1), it states "the contribution ... is allocated to the account balances of ..." Later in that same paragraph, three more times it states "to the account balance(s)" Under this One-to-One correction method, could a plan sponsor allocate the QNEC only to eligible NHCEs that have account balances (meaning the Eligible NHCEs with a zero account are excluded)? -
Rerunning 2011 ADP for a plan due to issues with ownership changes we weren't aware of. Long story, but ERISA attorney has advised we are to split plan into 4 separate ADP tests. 1 of the ADP tests is failing, other 3 are passing. However, I performed the testing by disaggregating the otherwise excludable nonHCEs. Obviously, corrections are being made more than 12 months after plan year-end. EPCRS states that plan may not be disaggregated into component plans for determining the correction for failure. ERISA Outline Book indicates the prohibition against restructuring is because the IRS doesn't want employer to reduce the amount of corrective distributions to HCEs and thus the amount of the one-to-one contribution for nonHCEs. QUESTION: Is the EPCRS saying that it is OK to disaggregate to run the tests, but if the test fails then I have to add back the disaggregated nonHCEs before I determine the refunds for the test that is failing (which is what I have always thought was the case...)? Or am I to understand that I can't disaggregate at all when I run the tests in the first place? Thanks!!
