Editor's Note: This is the eleventh installment in a series concerning correcting plan loan failures.
Q. What about loans to seasonal employees who are off from May 15 to Oct. 15 every year?
A. This issue has been posed to the IRS and they have never provided any exceptions for seasonal employees. So an employer would need to make arrangements for seasonal employees to make payments (e.g., ACH) during the periods when they are “off.” Alternatively, if the plan can pass the nondiscrimination requirements, they could exclude the seasonal employees from loans.
Editor’s Note: This content is taken from “Loans: Correcting Taxation, Qualification and Fiduciary Failures,” an April 15, 2020 ASPPA Webinar presented by Stephen W. Forbes J.D., LL.M. of Forbes Retirement Plan Consulting.
Opinions expressed are those of the author, and do not necessarily reflect the views of ASPPA or its members.
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