thepensionmaven Posted May 17, 2017 Posted May 17, 2017 Employer terminating 401K 6/30/2017, no employee contributions after that date. Can safe harbor for 2016 be made by 9/15, which is after the termination date w/o jeopardizing the plan term?
Tom Poje Posted May 17, 2017 Posted May 17, 2017 look at it from a different point of view. let's say plan simply froze on 6/30 you still have to fund the plan through that date, but when it gets funded is a different matter. the only thing the term date 'implies' is that distributions will occur 'within a reasonable time' years ago at an ASPPA Conference the IRS indicated if they didn't take place within a 'year' then you may have issues like "You need to provide top heavy through 12/31"
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