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Posted

What plan year is a contribution attributable to and whether it's based on the dates the money was earned or based on the date of the paycheck.

Posted

Using "date earned" would be a logistical nightmare for those times when it may be earned partially in December and partially in January. Therefore, almost always, any paycheck is defined by the paydate

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.

Posted

this could depend on your document wording

for instance a number of documents have the following language (This was from a 415 amendment as required from a few years ago)

Administrative delay ("the first few weeks") rule. 415 Compensation for a limitation year shall not include, unless otherwise

elected in Section 2.2 of this Amendment, amounts earned but not paid during the limitation year solely because of the timing of

pay periods and pay dates. However, if elected in Section 2.2 of this Amendment, 415 Compensation for a limitation year shall

include amounts earned but not paid during the limitation year solely because of the timing of pay periods and pay dates, provided

the amounts are paid during the first few weeks of the next limitation year, the amounts are included on a uniform and consistent

basis with respect to all similarly situated participants, and no compensation is included in more than one limitation year.

so if the last item here was checked then it is included in 'prior' year

415 Compensation. (select all that apply):

a. [ ] Exclude leave cashouts and deferred compensation (Section 3.2(b))

b. [ ] Include military continuation payments (Section 3.2©)

c. [ ] Include disability continuation payments (Section 3.2(d)):

1. [ ] For Nonhighly Compensated Employees only

2. [ ] For all participants and the salary continuation will continue for the following fixed or determinable

period:

d. [ ] Apply the administrative delay ("first few weeks") rule (Section 3.3)

...........................

It is all or nothing. You can’t treat some people one way and some another way.

Let’s say you deferred 10%. You quit 12/8/2013. Your final paycheck show up in January 2014. Let’s suppose you never worked again. When you file taxes, you would file that check for 2014, even though you didn’t work in 2013. So generally, the same thought process applies to the plan year. It is the W-2 comp that falls within the plan year, not the calendar year.

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