30Rock Posted December 27, 2018 Posted December 27, 2018 Sponsor deducted final deferrals from the wrong payroll file, and thus many participants who had increased their deferral elections were missed. The IRS EPCRS guidance states if corrected within 3 months no QNEC is due for the deferrals, a QNEC for the missed match if any must be made and there is a notice. However this is not their concern, they want to know how to correct for the missed deferral deduction opportunity? Is there a W2 or accounting method they could use to fix this like offset some of their pay from the 1st payroll in 2019 so they can make 2018 deferrals? I have not had this issue come up before so any thoughts would be appreciated.
Larry Starr Posted December 28, 2018 Posted December 28, 2018 21 hours ago, Lou S. said: Re-run the payroll? Agreed; the only thing they can do to make it work for 2018 is to FIX THE MISTAKE by doing it correctly now, before 12/31. Lawrence C. Starr, FLMI, CLU, CEBS, CPC, ChFC, EA, ATA, QPFC President Qualified Plan Consultants, Inc. 46 Daggett Drive West Springfield, MA 01089 413-736-2066 larrystarr@qpc-inc.com
RPAS Posted December 28, 2018 Posted December 28, 2018 Best practice and "cleanest" process would be to do the QNEC on the deferrals, missed match and true up for any missed market earnings. The employees should not have to suffer from what could be large deferral amounts from one or more paychecks due to a payroll error. They are missing out on the tax savings from these missed deferrals, which is why it would be best practice for the company to take the hit vs. the employee.
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