How are corrective distributions treated for top-heavy determination p

[John A]

How are corrective distributions treated for top-heavy determination purposes? Are they treated like any other distribution? Does it make any difference if the corrective distribution is for excess contributions, excess aggregate contributions, excess deferrals, or 415 excesses?

[Guest]

I learned (and that doesn't mean it is correct) that you include all amounts that would be included as annual additions. This would seem to make sense. An excess contribution or excess aggregate contribution are included in the ADP test, etc. so why not include them in top heavy.

excess deferrals are getting off into the realm of 'maybe', though if returned by April 15th they are not treated as an annual addition. after that date I would count them.

finally, since you can't exceed annual additions, I would not include deferral distributions that are due to 415 violations - treat 'e as if they didn't really exist.