R. Butler Posted November 7, 2012 Posted November 7, 2012 Took over a plan that failed ADP in 2010, but did not make refunds. Plan was also top-heavy, but the required minimum contributions were not made. They will correct the ADP by issuing refunds and making a QNEC contribution of the same amount. Can that QNEC be used to reduce top heavy minuimums for 2010 also? Thanks in advance for any guidance.
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