Look Back for Distributions Top Heavy

[Guest ROB VIDOVICH]

EGTRRA 613© Look Back for Distributions

For plan years beginning after 2001, any distribution processed after the determination year to be included in the top heavy calculation are In-service distributions only in which the 5 year look back will apply...

So this means if there were distributions processed for the year 2000 and prior years for Key and Non-Key employees that were due to separation of service, death and disability these distributions can "not" be included in the Top Heavy calculation for the 2002 Plan Year????

[Tom Poje]

correct, and it is not just distributions. An ee who has not performed service during the one year period is also excluded