Treatment Of ADP/ACP Corrective Distributions Under Post-EGTRRA Top-He

[Guest GAPPension1]

Is it reasonable to treat ADP/ACP corrective distributions to HCEs as in-service withdrawals for the plan year the distributions were actually made for post-EGTRRA top-heavy purposes?

I believe it is, but guidance I have looked up on the matter is a bit unclear.

[R. Butler]

We do. Question was submitted to the IRS at 2002 ASPA Annual Conference. The IRS concurred (see Q&A 3 of the IRS Questions and Answers; its available on the ASPA website.)