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ACP Testing for Safe Harbor Plan That Suspended Match Contributions
PLANSPONSOR; free registration may be required Link to more items from this source
Nov. 3, 2020

"[F]or safe harbor plans that suspend their safe harbor matching contributions, the IRS does NOT permit prior-year testing, only current-year testing (where the NHCE ACP for 2020 would be compared to the HCE ACP for 2020). If your plan was NOT a safe harbor plan, it could use prior-year testing if that method was stipulated in the plan document."

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