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I have a client who failed to include a non-cash item (trip) in the comp of several employees and therefore said employees did not have the oppty to defer on those bonuses. The plan uses the 415 safe harbor of comp with no exclusion of bonus.

I believe the only fix is to treat this as a missed deferral oppty and have the sponsor make the corrective contribution. (assuming employees aren't already maxed out, comp isn't above comp limit etc).

Any other creative suggestions?

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