Dalai Pookah Posted April 25, 2018 Posted April 25, 2018 A plan failed to allow deferrals for some participant beginning in 2015 and continuing to 2017. On plan correction, how do we interpret Rev. Proc. 15-28, which allows correction using a 25% QNEC if within the SCP time limit for significant errors (last day of the 2nd plan year). It is clear that for 2015, the 50% QNEC correction applies, since 2018 is beyond the 2-year deadline. The question is for years 2016 and 2017. Are each of the missed deferrals treated as discrete and therefore eligible for the 25% safe harbor correction or are all missed deferrals considered part of a continuous whole and all subject to the 50% QNEC correction? Please direct me to any citations to support your answer.
Adi Posted April 27, 2018 Posted April 27, 2018 Check out this thread and see my post that links to the q/a:
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