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Posted

A HCE is due to receive an ADP refund as the result of the 1/1/2004 to 12/31/2004 ADP test. The HCE would have turned 50 during the plan year (12/1/04), but died on 11/5/04.

Can the refund be re-classified as catch-up deferral money based on him turning 50 during 2004? Or will the refund will be issued based on being deceased at age 49?

Thanks for any help!

Posted

... assuming that is authorized in the plan document.

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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