coverage for employer contributions not made

[Guest ERIC STRAND]

How do you complete the Schedule T for a Plan that allows discretionary profit sharing contributions or matching contributions if no Employer contributions are actually made? Can you use the exception code that say's that no HCE are benefiting since no HCE received an Employer contribution? Alternatively, should you use the exception code that say's that all non-excludable NHCE are benefiting if they actually would have all benefited if an Employer contribution had been made?:confused:

[R. Butler]

I am assuming this is a 401(k) plan that benefits all nonexcludable employees. If my assumption is correct, then per the instructions to Schedule T, line 3 (specifically the "Note" located under line 3), we check both box 3B and 3D. 3B because no HCE's benefit under the 401(a) and 401(m) sections; 3D because all NHCE's benefit under 401(k).

If 401(k) does not meet any of the exceptions for line 3, then Skip line 3 for all parts and go to line 4.

[Guest ERIC STRAND]

Thanks for your help. I was assuming that you couldn't check any exception code in part 3 unless it applied to every portion of the Plan. Actually, the instructions appear to say that you can check more than one box if every part of the Plan is covered by at least one (not necessarily the same) of the exception codes. That simplifies my life a little.