Guest KevinP Posted February 18, 2004 Posted February 18, 2004 Under the post EGTRRA rules, we are to add back the in-service withdrawals that occured for the the determination year and the previous 4 years. This does not distinguish between Key and Non-Key, so I read this to mean you add back all in-service distributions for the period regardless of their status as key employee or non-key. Did I read this wrong? And is it still a grey area regarding ADP and ACP corrective distributions? I see where the IRS made a comment at the ASPA conference, but has there been any other clarification on this issue? Thank you for submitting your responses.
Mike Preston Posted February 18, 2004 Posted February 18, 2004 I believe you add back regardless of HCE/NHCE status. I also believe that ADP/ACP corrective distributions are added back to the extent they are actually distributed to the participant in question. If they are forfeited, I don't think they count as distributions to be added back.
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