top heavy test: include PS rec'ble?

[doombuggy]

Plan is new - started 1/1/14. It has almost $71,000 in profit sharing receivables as of 12/31/14. No other type of receivables.

Would you include the PS rec'bles in the top heavy test?

There were also rollovers into this plan of a significant amount. I have them marked as a regular/outside rollover. They came from a terminated plan but from a different plan sponsor - company name and EIN entirely different. Because of this, I did not mark them are related. I assume that all participants were given an option to roll the money from the old MPP under the other company to this new plan or put it into an IRA.

Thanks for your thoughts.

[mphs77]

The other entity my have a different EIN, etc., but are you sure they were not owned by the same persons and possibly a controlled group with the current Plan Sponsor?

[Tom Poje]

well, if you follow the regs, 1-416-1 T-24 says

....However, in the first year of the plan, the adjustment should also reflect the amount of any contributions made after the determination date that are allocated as of a date in that first plan year.

As far as I recall, most would hold that means you include the receivable.