Randy Watson
Aug 5 2009, 01:39 PM
Is there a problem with using forfeitures to make a corrective contribution (assume the plan specifically allows for it)?
BG5150
Aug 6 2009, 08:09 AM
If the plan specifically allows for it, I see no problem with using forfeitures to make a corrective contribution...
J Simmons
Aug 6 2009, 12:58 PM
Rev Proc 2008-50 addresses the use of forfeitures, if the plan permits, in a corrective allocation situation (6.02(4)(c)) but makes no mention of use of forfeitures for a corrective contribution. The fact that the use of forfeitures (if plan permits) is addressed in one context but not the other, and the numerous references throughout Rev Proc 2008-50 to corrective contributions couched in terms of such being made by the employer leads me to be a bit cautious on this issue. I would not use forfeitures for a corrective contribution unless the VCP reviewer expressly permits such.
**grammar corrections**