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TOP HEAVY PLAN IN-SERVICE DISTRIBUTION


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Guest ROB VIDOVICH
Posted

A COMPANY HAS A 401K PLAN WITH DEFERRALS AND AN ANNUAL 1% EMPLOYER PROFIT SHARING CONTRIBUTION TO ALL ELIGIBLE PARTICIPANTS.

The plan is Top Heavy for 2002 based on the 2001 balances and the In-Service withdrawal for the Key Employee.. Also, the highest contribution percentage contributed by key employees is 3.77% (2.77% Deferrals and 1% Employer P/S Contribution).

1. With the new top heavy rules how long would the In-service distribution taken by the Key Employee in 2001 have to be included in the Top Heavy test 1 year look back or would the 5 year look back rule apply?????

2. Since every eligible participant will receive the annual 1% profit sharing contribution, would an additional 2% need to be contributed to non-key employees to meet the 3% top heavy minimum???

Posted

1. Five year look back rule still applies to in-service distributions.

2. Yes. ( I assume no matching contributions are made based on your 3.77% calculation.)

Posted

I might be wrong, but I don't think the P/S contrib counts as a key empl. contribution. therefore i think the highest contrib would be 2.77%

Remember: two wrongs don't make a right, but three rights make a left.

Posted

Yeah, I'm wrong. I guess I had one of my patented brain farts. Seems like I'm having a lot of those these days. Maybe I need a vacation.

Remember: two wrongs don't make a right, but three rights make a left.

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