Top Heavy Balance with ER Contribution after the end of the plan year

[justatester]

Top Heavy Determination Date of 12/31/2025 for calendar year plan. (not a first year plan)

Client funds a 2025 Plan year contribution in 3/2026. 

Is the contribution funded in 3/2026 included as a receivable in the 12/31/2025 balance?

 

[mming]

It's my understanding that all contributions for a certain plan year are considered to be credited to the plan as of the last day of the year, even if they are deposited in the following year, so they would be included.

[John Feldt ERPA CPC QPA]

If you’re asking about a top-heavy test, my understanding is that you count receivables at the end of the first plan year, but thereafter, they are only counted if subject minimum funding requirements under section 412. Of course, I could be remembering that incorrectly, but I’m sure the 416 regulations explain how to handle it.