10/9/2014. Learning Lab 6. Catch-up Contributions: The Good, The Bad and The Fiscal Year
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1 Learning Lab 6 Catch-up Contributions: The Good, The Bad and The Fiscal Year 1
2 Why Use Catch-Ups Additional saving opportunity Not included in ADP testing (if exceed plan limit, 402(g) limit or 415 limit) Not part of 415 limit 3 How Much Increase (k), 403(b), Federal Thrift Saving and most 457 plans - $5,500 SIMPLE Plans - $2,500 IRAs - $1,000 Note: Our discussion will focus on 401(k) plans 4 2
3 Code 414(v) - Attainment of Age 50 You are considered age 50 for the entire calendar year containing your 50 th birthday Technically, you can make catch up deferrals before your actual 50 th birthday Even if you sever employment or die before actual birthday these are still catch-ups For non-calendar year plans: a participant is catch-up eligible as of January 1 of the calendar year in which the participant reaches his or her 50 th birthday 5 You Must Exceed a Limit Four ways to be catch-up eligible Exceed 402(g) limit Exceed Plan limit ADP Test failure Annual Additions We will discuss each of these in more detail 6 3
4 Plan limit Plan Limit Example: The employer sets a limit on deferrals of 5% of compensation Plan document terms may stipulate that the Plan Administrator will establish the plan limit for HCEs in order for testing to be passed. 7 Plan Limit Can I set plan limit at $0 Well.proposed regs seemed to indicate that you could but the specific example was omitted from final regs Can I use a very, very low limit presumably But you would limit the deferrals to the catch up limit is this really what you want to accomplish? 8 4
5 In Case a Participant Asks Can anyone really defer 100% of pay? No Due to FICA/FUTA, other benefit withholdings, etc. 9 Failing ADP Testing No choice! - Employee must recharacterize as catch-up Example If a failed ADP test refund of $6,400 of 2014 deferrals is determined to be needed to pass the test, then the first $5,500 must be recharacterized as catch-up (unless catchup has already been contributed) 10 5
6 Exceeding 402(g) Limit, PY-End Breaking the 402(g) limit is theoretically not determined until PYE but it can be funded throughout year But watch out if the employee never actually exceeds the projected limit then what they thought was catch-up is not 11 Breaking 415 Limit Example If participant does not exceed the $17, (g) limit but exceeds the 415 annual additions limit of $52,000, deferrals will be recharacterized as catch-up (up to the catch-up limit) Example $17,500 Participant deferrals $17,500 Match $23,500 Employer nonelective contribution $58,500 Total annual additions for 2014 $5,500 excess annual additions handled by deferrals being recharacterized as catch-up. plan matches on catch-up, (if plan did not match on catchup - plan may permit match to stay, or may not) 12 6
7 Excluded from ADP testing Takes $17,500 limit and makes it $23,000 Excluded from annual addition limit $52,000 for 2014, plus $5,500 of catch-up = $58,500 Reported to IRS on W-2 13 Top Heavy plans Current year do not include catchup contributions Prior years catch ups are part of the account balance used in TH determination 14 7
8 If plan is a non-calendar year then use the catch-up limit in effect at the end of the PY For non-calendar year plan, catch-ups affect for both the calendar year and fiscal year (see next slide) 15 June 30 PYE 2013 Defer $10,000 from 1/1 to 6/ defer $10,000 from 6/30 to 12/ defer $10,000 from 1/1 to 6/30 Note - $2,500 of the deferrals from 6/30 to 12/31 are catch-up and not in ADP test 16 8
9 June 30 PYE 2013 Defer $10,000 from 1/1 to 6/ defer $10,000 from 6/30 to 12/ defer $10,000 from 1/1 to 6/30 Note if fail 6/30/14 ADP test catch up amount is assigned to If I am in two or more plans (different employers) I may not exceed deferral limit in each plan But in total I may exceed $17,500 Example defer $14,000 each into two plans Neither plan has to treat the amount as catchup But I can only deduct - $23,
10 Universal Availability Requirement Universal Availability All of employer s plans must offer catch-up, except: Collectively bargained employees Nonresident aliens with no US sourced income 19 Additional Rules One limit per person, like 402(g) If in multiple plans during year, either by changing employer or within a controlled group, there is a limit of one catch-up amount One catch-up for all my 401(k) and 403(b)s Exception of governmental 457(b) plans Can have a separate catch up for this plus my 401(k)/403(b) catch up 20 10
11 Additional Rules No special election by participant is necessary Catch-ups are automatic 21 Questions Had Enough for one day Thank you for your attendance and participation 22 11
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