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A plan is effective for the first time 1/1/2020 and is not Safe Harbor. The owner is over 50 and contributes $4,000. There are no other employees contributing and her ADP refund will be recharacterized as catch-up. For the 12/31/2020 Top Heavy test, is her balance excluded from the ratio because it is characterized as catch-up? Is the plan considered Not Top Heavy at 0% for 12/31/2020 (2020 and 2021 plan years)?

Any guidance is appreciated! Thanks!

 

 

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