415(c)(4) Business Explanation Needed

[Guest TACLord]

Employee contributions (voluntary and mandatory) are not deemed credited to a participant's account for a particular limitation year unless the contributions are actually made to the plan no later than 30 days after the end of such limitation year (see Reg. 1.415-6(b)(7))

For a 401(a) plan what would be an example of this occuring and must this rule be automatically applied. We receive contributions thru payroll deduction. I can't believe that in the situation where aftertax contribiitons are submitted > 30 days after the payroll end date and the fiscal year has ended, that the contributions needs to be applied to the current fiscal year rather than the prior year.

Assuming this is true then what about attribution to the plan year for purposes of ACP testing?

Thanks

[ak2ary]

Were these contributions by check from the participant or withheld thru payroll?

[Guest TACLord]

Were these contributions by check from the participant or withheld thru payroll?

I belive that (after discussing this in depth) with the recordkeeper that it was an individual check received. Which makes perfect sense in applying the rule expalined in 415©(4).

I just can't understand how money can be deposited via an individual check and not thru payroll deduction. Just wouldn't be prudent (or legal).

I belive we can just close this thread.

Thanks