Covered Employee if “Tested Out”

Looking to confirm IRA deductibility rules in this scenario:

  • A 401(k) plan exists, but due to “testing” (my guess is ADP/top-heavy test), a highly compensated/key employee isn’t allowed to contribute this year.

  • I believe the employee is still technically eligible under the plan.

  • Income is above the range for IRA deductibility if “covered” by a workplace plan.

Questions:

  1. Is the employee still considered “covered” even if they’re excluded from contributing this year?

  2. If yes, does that trigger IRA deduction phaseouts based on income?

Thanks for any insights!



If no contribution is made to the plan and no forfeitures or profit sharing contributions are made to the employee’s account, they are not an active participant.

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