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Posted

I know this should probably be a basic question, but I've been struggling with it a bit...client has a calendar year 401(k), but the fiscal year ends March 31st. They never utilized the profit share feature, but a discretionary profit share has always been available in the plan. (Plan doc is a standard prototype). They want to start profit share contributions, but would like to base the profit share allocation on the fiscal wages, not calendar. Document defines comp as W-2 with adjustments for all pre-tax. Is there any reason that we can't allocate the ps on fiscal comp? We get quarterly payroll, so the data is there but I'm thinking that the plan doc does not ask separately for comp used for allocations. Does this mean the plan doc would have to be changed to a non-standard or individually designed? thanks in advance for any/all replys...

Posted

Why not define the determination period for compensation as the fiscal year for all purposes?

...but then again, What Do I Know?

Posted

The client wants the 401(k) portion to match up to the W-2 info because it gives the participants a double check between the W-2, plan statement and investment statement they receive. I don't know if there were maybe problems in the past on the deferral side (we are taking this plan over). We use Relius and can code fiscal wages in for allocation purposes while using W-2 for ADP/ACP and reports but I didn't know if this was ok or if the plan had to state....

Posted

The plan document specifies the determination period to be used. While I have seen prototype documents that allow different definitions of compensation for distinct purposes, I am not familiar with any that allow multiple determination periods.

...but then again, What Do I Know?

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