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Restoring lost earnings on tardy matching contributions; are these amo


Guest tmconn

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Posted

My company failed to fund matching contributions timely, and is therefore restoring the earnings lost on the unfunded match. My question is, is this a QNEC or is it simply lost earnings, which are not considered for the purposes of annual additions and ADP/ACP testing?

Guest MTransue
Posted

I'm curious as to more background information regarding the scenerio... What is the plan year end? Has the employer filed it's corporate tax return? Was there a positive return on your assets for the plan year?

The earnings wouldn't be included in the ADP/ACP test. Nor would they be considered for the 415 or 410(B) coverage tests.

However, in IRS Rulings I've seen, the earnings are not deductible under IRC 404.

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