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Posted

Hope everyone is practicing safe social distancing.

We have a participant who makes contributions to 2 plans. We administer one of the plans.

He is an HCE and receives an ADP refund in the plan that we administer.

Later he provides proof of combined excess deferrals between both plans.

My question is whether the 402g excess deferral refund is a refund in addition to the ADP refund, or can the 402g excess be included as part of the ADP refund?

Posted

It looks like everyone has distanced themselves from your post :) 

Seem to me that it's two payments because of the 1099-R reporting. The ADP refund will be taxable in 2020 - code 8. If the 402(g) excess deferrals are returned by April 15, that amount is taxable in 2019 - code P. 

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