Client wants to make additional integrated non-elective contribution o

[KateSmithPA]

My client has a safe-harbor 401(k) plan. He contributes the 3% non-elective contribution. He wants to make an additional non-elective contribution and have it integrated. Can someone explain how that works? Can he count the 3% safe-harbor contribution in the base percentage for his integrated contribution?

[wmyer]

The 3% non-elective cannot count towards the base for integration. If the client wants to give, for example, a 4.3% integrated contribution in the profit-sharing/Safe Harbor 401(k) plan, then he'll have to give an additional 4.3% profit-sharing contribution. (Pursuant to IRS Notice 98-52.)

[MWeddell]

Another theoretical possibility is doing 401(a)(4) testing, presumably on an age-weighted basis, without imputing permitted disparity on the 3% contribution used for the 401(k) safe harbor. Of course, the chance that your client wants a general 401(a)(4) testing situation when the plan is designed to avoid the ADP test seems fairly remote.