Current vs Prior Year testing

[Guest CGBS]

Is my understanding correct - I can use either current or prior year testing for tests I am now running for 12/31/00.

And I have until the end of the GUST remedial amendment period (ie. 12/31/01) to make a commitment to which way I do testing in the future? For example is it ok to use prior year data for 12/31/00 and switch to current 12/31/01? Or current for 12/31/00 and prior for 12/31/01?

However, if I want to make a qnec for 12/31/00 I must use current data right?

Many thanks for clarification!

[MWeddell]

Yes, you've got until the end of the GUST remedial amendment period (12/31/2001 for calendar year plans) to freely switch back and forth. Make sure your plan document correctly lists which method you used for which year. Note that the method you use for the 2001 plan year will constrain your choice for 2002, so in a sense the period when you freely switch back and forth ends with 2000.

QNEC timing tends not to work well with prior year testing. If you want to make a QNEC now for a plan year ended 12/31/2000, then you need to use the current year testing method.

Good luck!

[Guest CGBS]

Thanks for the help!