I have a client who has 401k plan and realized in 2017 plan year that they missed deferrals for a participant in 2015 and 2016 plan year. Now they have calculated missed deferrals and match amount along with earnings.
Question is:
1. Can this QNEC amount be included in ADP\ACP test?
2. If yes for above, can 2015 and 2016 QNCE amounts be included in 2017 ADP\ACP tests or only can be included in their respective plan year testing. In this case as they have already completed 2015 and 2016 testing thus these amounts are not included in any testing year, is it ok or IRS has some guideline for the same.