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NFP need an extension to deposit ER ctb after 5/15?


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For a calendar year NFP 403b plan, they want to make their deposit sometime in August (for Reasons).  But they intend on filing their 990 at the regular deadline (5/15/24, 4.5 months after the end of the year).  I know that in the for-profit world, this means that they can't take the deduction for it in the prior year, so they might run into a 404 issue in 2024.  Does that apply to a NFP?  Any part?

Thanks.

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https://www.nfp.com/insights/what-is-the-real-deadline-for-making-plan-contributions/

Here is a great article on all those rules. For-profits have 30 days after the tax return due date including extensions for a deposit to be considered an annual addition for the prior year. Tax-exempt entities have 9 1/2 months after their fiscal year end, which is 10/15 for calendar fiscal years (be careful if plan and fiscal years are different, and which is your limitation year). In your situation, an August deposit poses no issues if your relevant years (plan/fiscal/limitation) align.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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