Rev. Proc. 2015-27

[Belgarath]

Re the correction for 415© violations under the new Section 4.04 in RP 2015-27.

Is this limited to plans that do NOT provide matching contributions? The language could probably be read either way. I'm not sure if this is meant to act as an example, or if it is meant to limit it only to plans with no match. Any opinions?

"A plan that provides for elective deferrals and nonelective employer contributions that are not matching contributions is not treated as failing to have established practices and procedures to prevent the occurrence of a 415© violation in the case of a plan under which excess annual additions under 415© are regularly corrected by return of excess deferrals to the affected employee within 9-1/2 months after the end of the plan's limitation year."

[Kevin C]

I read it as applying to plans that provide for both deferrals and profit sharing contributions. I don't see it as being limited to plans that do not provide a match. I do think it would not apply if the plan only provided for deferrals and a match. Not that it affects the question, but the same language was in 2013-12, the only change was from a 2 1/2 month correction period to a 9 1/2 month correction period.

[Belgarath]

Thanks Kevin.