Section 404(a)(6) requires a grace period contribution be on account of the preceding taxable year and be made by the employer’s tax return due date including extensions. IRS ruled that a pension contribution must be able to be used for funding purposes for that prior year in order to be on account of that year. The deadline for making a contribution for a calendar year plan for 2016 funding is September 15, 2017 while the extended corporate calendar return due date is October 15, 2017. Employers must consider the different plan funding deadline when planning pension contributions.
US Tax Marketing Leader, PwC US