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Wrong Comp. - QNEC - Testing


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Guest philc
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Plan defined compensation to include bonuses. For their 2003 calendar year/plan year, the employer did not withhold deferrals on the bonus and their Match did not take bonuses into consideration. They failed ADP/ACP for 2003.

The employer will be making a QNEC to correct the shortage of deferrals and an additional employer contribution to correct the Match. Prior year testing if that matters.

Must the 2003 ADP/ACP tests be re-run to reflect the corrective amounts? What about any excesses that have already been distributed due to the failed 2003 tests?

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