ATM 3/15 Deadline?

[justatester]

Are ATM corrections subject to the 3/15 deadline? (for 1/1 plans)

 

[Lou S.]

ATM? do you mean ADP/ACP refunds? if so the deadline is 2 1/2 months assuming no extension for auto enrollment to avoid the 10% excise tax on late refunds.

I believe the IRS position on that is 2 months plus 15 days so I think if the PYE is 1/1 (as opposed to 12/31) you would technically have until 3/16.

[justatester]

Attributable Match associated with an ADP refund.

 

 

[Lou S.]

I believe the attributable match has the same deadline as ADP refund though I'm not sure I can find a cite to affirmatively support that.

[Bri]

Failure to distribute the related match ends up as a 401a4 issue, though, right?  It's not really a corrective distribution occurring when it's simply the match being forfeited.  Not sure if that buys you any extra time beyond 3/15 though.