Catch-Up for fiscal plan

[Cynchbeast]

We have fiscal 401(k) plan, PY 07/01/14 through 06/30/15. The owner's deferrals are all after 01/01/15, and he turns 50 in October, 2015.

1. He will definitely defer $18,000 limit for 2015 before PYE.

2. Since he will be 50 by 12/31, he will be eligible for $6,000 catch-up for 2015

Q: Can he make his catch-up deferrals before the 06/30/15 PYE or does he have to wait until after 07/01/15 - which would be the plan year containing 12/31/15?

[Lou S.]

He can fund the full $24,000 from 1/1/15 - 6/30/15.

For ADP purposes his deferral would be $18,000 (since you state he has no deferrals from 7/1/14-12/31/14) as $6,000 is catchup and not subject to testing.

[Tom Poje]

I would not use the expression "can he make catch-up contributions"

I thought it was simply a matter of deferring, and then, if any of the deferrals were greater than a limit - 402(g), plan imposed limit, failed ADP test, those amounts are then treated as a catchup