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ADP/ACP test refunds


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Posted

Situation is 98 discrimination test failed, refunds need to be processed in order to make the test pass.

Are refunds due to HCE's after April 15 subject to 98 or 99 taxation? Are there any other ramifications to consider?

Guest TrustMe401k
Posted

Excess contributions and applicable income returned after April 15th are includible in gross income for the year in which they are distributed. So in this case, for 1999. Also, the company owes a 10% excise tax on the total for returning money after April 15th. The excise tax can be avoided if the company makes QNEC's or QMAC's enabling the plan to pass the ADP test even if they are made more than 2 1/2 months after the end of the plan year.

Guest GregSelf
Posted

Make sure you're clear on the dates. If we're talking about a 12/31 plan year end, the date used to determing the taxable year and the excise tax is March 15, not April 15.

Guest GregSelf
Posted

Also keep in mind, the 10% excise tax is based on just the refunded contributions and not the earnings.

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