Scuba 401 Posted June 15, 2017 Posted June 15, 2017 if a safe harbor nonelective plan allows after-tax but does not have a match, does it have to pass the ACP test?
ETA Consulting LLC Posted June 15, 2017 Posted June 15, 2017 Of course it does. Good Luck! CPC, QPA, QKA, TGPC, ERPA
austin3515 Posted June 15, 2017 Posted June 15, 2017 Which is why the people in your plan who want to take advantage of the new after-tax to Roth conversions won't be able to :) Austin Powers, CPA, QPA, ERPA
CuseFan Posted June 16, 2017 Posted June 16, 2017 exactamundo - that trick only really works with solo plans Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
spiritrider Posted June 16, 2017 Posted June 16, 2017 I wouldn't say it only works with solo plans. It really depends on the census and the propensity of NHCEs to take advantage. The last plan I had at a mega-corp did not match after-tax contributions and had to limit HCEs to 5% after-tax contributions. Cause and effect, I have no idea. However, allowing a match to apply to after-tax contributions might influence NHCEs enough for the plan to pass testing or at least allow some reasonable contribution percentage for HCEs.
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