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Posted

I have a client who deposited a 2012 contribution in 2011, Is this allowed? Would it be listed on the 2012 SB with the date in 2011?

Any comments would be appreciated.

Thanks!

Posted

(1) It certainly can be deducted in 2011 (or 2010 if made before the 2010 FIT return was due); you'd need to check the carryforward rules to determine if deductible in 2012.

(2) It would be reported on 2011 SB. It could be added to the 2012 PFB and used to offset the 2012 MRC provided the 2011 (FTAP-PFB)/FT >= 80%. If less than 80%, client would have to make a contribution in 2012.

(3) For FASB purposes, it would be a 2011 contribution

(4) It would have been in the assets 2012 BoY to determine the AFTAP if the Plan requires an AFTAP certification

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

Posted

No. Contributions on the SB must be for the plan year. You might consider whether the 2011 SB should be amended.

Gray Book Q&A 2003-4 has a similar discussion, and part of the answer is:

"No. A contribution made in 2002 to a calendar year plan cannot be included on the 2003 Schedule B."

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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