Matching Contribution Deposit Deadline

[Guest dll]

It is my understanding that matching contributions need to be made to the plan by the due date for the corporate return plus extensions unless it is a QMAC and then it is due by the end of the following year (plan year and fiscal year the same).

I'm confused that Treas Reg sec 1.401(m)-1(B)(4)(ii)(A) refers to making the contribution 12 months after the plan year end. Can someone clarify this for me. Thanks.

[jpod]

The regulation which you cited prescribes a deadline for making matching contributions for a plan year, in order for them to be treated as "matching contributions" for purposes of nondiscrimination testing (i.e., subject to ACP testing rather than general 401(a)(4) testing).

The cited regulation does not address tax deduction deadlines, or the timing rules for treating contributions as "annual additions" for a particular limitation year. For example, the due date of the employer's tax return, plus extension, is the deadline for making contributions that are deductible for the employer's tax year covered by that tax return.

Yes, it's a bit odd that the two deadlines are not in sync. (BIG SURPRISE!)