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Posted

Employer has a SIMPLE-IRA, but inadvertently excludes an employee for all of 2014. This will be corrected in 2015 via a make-up contribution. Is employee an "active participant" in a plan for 2014 for determining deductibility of any IRA contribution?

Unless I'm off base, under 1.219-2, it is the later of the date the contribution is made or allocated. So since made - or will be made in 2015, then not an active participant for 2014. Any other thoughts?

Posted

Did the employer check the "Active Participant" box on the employee's 2014 W-2?

Not that it's right but that's how the IRS computer will test for IRS deductibility

Posted

Is been a while but I thought the rule for active participation in a DC plan was whether a contribution was made to employee's account in the tax year not whether he was eligible to participate under the plan. Why not just change the w-2 for 2014?

mjb

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