jkharvey Posted March 24, 2015 Posted March 24, 2015 Does this QNEC contribution for the missed deferral opportunity of one nonekey remove the Top Heavy exemption for the plan?
Kevin C Posted March 26, 2015 Posted March 26, 2015 I don't think it does, but I doubt you will find anything addressing the question. The purpose of the corrective QNEC is to put the plan where it would have been if the error had not been made, or at least close enough to satisfy the IRS. I think that as long as this correction method has been around, the IRS would have said something by now if they thought their correction created a TH issue. It also doesn't make sense that a correction of salary deferrals in a SH plan could cause the TH minimum to apply.
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