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Posted

Running the ADP test for a traditional 401(k) plan based on compensation net of salary deferrals. A participant has compensation of $300,000 so she is being limited to $275,000. When we reduce her compensation for $18,500 of salary deferrals, is it subtracted from $300,000 or the $275,000 of limited compensation?

Thanks.

Posted

You subtract out the deferrals before applying the 401(a)(17) limit.

Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance.

Corey B. Zeller, MSEA, CPC, QPA, QKA
Preferred Pension Planning Corp.
corey@pppc.co

Posted

(And of course, if you're netting deferrals, you're netting ALL deferrals, including stuff like 125 plan amounts, if you want to remain a safe harbor comp. definition)

Posted

Whoa, under 414(s)(2) your plan document can elect to not count all deferrals (401(k), 125, 132, etc.) as comp, as Bri points out, but most plans include all of it. You need to check your plan document.

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

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