NW529 Posted December 4, 2020 Posted December 4, 2020 A participant is catch-up eligible and 415 compensation is $16,500. The participant deferred $8,750 and received a match of $8,750. Does the 415 test pass because $1,000 is re-characterized as catch-up?
BG5150 Posted December 4, 2020 Posted December 4, 2020 Yep ESOPMomma 1 QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
NW529 Posted December 7, 2020 Author Posted December 7, 2020 @BG5150 Thank you! We're also looking for some guidance on correcting a 415 failure for a prorated short year. The plan is terminating mid-December 2020. They have 100% of 90% match, but are not matching catch-up. They also made a 2020 Profit Share. Several employees have an excess 415. They are catch up eligible and contributed the catch-up. When following the correction steps, is the catch-up classified as "unmatched deferrals" and refunded first to cover the excess? Or, is the catch-up excluded and the regular deferrals are refunded and corresponding match forfeited?
BG5150 Posted December 7, 2020 Posted December 7, 2020 That I don't know. EPCRS has the 415 corrections. QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
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