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Posted

can someone point me to a page in the ERISA Outline Book where it discusses when employer contriubtions must be deposited to the trust in order to be treated as "relating" to a prior plan year?

It's clear as day when you're discussing 404 deduction limits, and 415 annual additions, but I can only find a vague reference to "the year in which the contribution is TREATED as allocated." 1.401(a)(4)-2©(2)(ii).

I don't think the 415 regs are necessarily always relevant because the limitation might not necessarily be the Plan Year.

Any help is greatly appreciated.

Austin Powers, CPA, QPA, ERPA

Posted

No where in there does it mention 401(a)(4)?? My frustration is that the rules regarding timing of contributions are spelled out so clearly for deduction issues (in the site you provided) and for 415 issues, but nowhere for coverage/nondiscrimination?

For waht it's worth, I know I have a deduction issue and a 415 issue for the Plan I'm working on. I'm trying to figure out if I have a nondiscrimination/coverage issue as well.

Austin Powers, CPA, QPA, ERPA

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