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Showing results for tags 'overlapping plans deduction considerations'.
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Facts: Employer has a 6/30 fiscal year and would like to install a SH 401k for the coming 6/30/2019 Fiscal Year end. In order to be a Safe Harbor plan for this year, it must be in place no later than 3/31. For 2018 the employer provided a SIMPLE plan. The 2018 employer contributions are to be deducted on the 6/30/2019 fiscal year return (as is required by SIMPLE plan rules of deduction -- cal year ending within the fiscal year provided contributed by due date of Fed return (incl exts)). Questions: Is this employer permitted to establish a new Safe Harbor 401k Plan (incl PS provisions) for its FY ending 6/30/2019 with a Plan Effective Date of 7/1/2018, thus full dollar limitations? Or, must it delay the effective date to 1/1/2019 since it had a SIMPLE thru 12/31/2018 (pro-rated limitations)? Thank you
