JKW Posted February 20, 2018 Posted February 20, 2018 Due to an error in the clients payroll system, a participants deferral was not taken for the plan years 2016 or 2017. They received their 3% SHNE, which was the only employer contribution. With the new 25% corrective contributions, can they still do this? I just want to make sure when it says "the last day of the second plan year after the plan year in which the failure began (which was 2016) - so that would be by 12/31/18 correct?
Madison71 Posted February 20, 2018 Posted February 20, 2018 Did the deferrals start-up? Notice is required within 45 days of starting correct deferrals to take advantage of 25% corrective QNEC contribution contributed by end of 2018 Plan Year
JKW Posted February 22, 2018 Author Posted February 22, 2018 They are starting the deferrals now. So they will mat the 25% qnec for 2016 and 2017. When we calculate the earnings - its it based on the 18,000 that should have gone in or the qnec amount?
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