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Top Heavy Plan


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Guest At Peace
Posted

May Qualified Match Contributions (QMACs) be used in satisfying top heavy minimums?

EGTRRA made changes so that match contributions can be used toward minimums without the problem of "can't be included in ACP" - does the same apply for QMACs? Can they be used toward TH minimum and still be used in ADP/ACP tests?

I am assuming they can, but can't find anything definite that states this.

Thanks in advance for your response!

Posted

EGTRRA simply says :

section 416©(2)(A) is amended by adding at the end the following:

"Employer matching contributions (as defined in 401(m)(4)(A) shall be taken into account for purposes of this subparagraph..."

since a QMAC is a match (see 1.401(k)-13) you should be able to use them for top-heavy purposes.

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