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Posted

We have a 12/31/2003 plan that failed the ADP test. A total of 10 HCE's require refunds. The client wished to issue 5 of them before the 2.5 months and the other 5 after the 2.5 months.

Is this possible?

Posted

Um, you are a couple of days late. Theoretically you should be able to do it. I can't think of any reg off the top of my head that states you couldn't.

Posted

Well, we had all of the checks already issued prior to the 2.5 months, but we are trying to make the determination, if indeed we can, to reflect the 1099's different for some of them.

Thanks for the response.

Guest Tinman42
Posted

I've had this request in the past and have complied with the employer's wishes. The plan did go through an IRS audit without any problems, so I think you'd be ok to do as the client requests.

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