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Scott
A client's DB plan defines compensation for benefit accrual purposes as "total salary or wages, excluding allowances and expense reimbursements." First question: Does that fall under a safe harbor definition?

Second question: If it is a safe harbor, would it remain a safe harbor if the definition were amended to exclude severance pay?
pax
I think the answer to both questions is Yes. check IRS regs. under 1.414(s).
AndyH
Just stumbled upon this while doing a search related to treatment of severance for testing purposes. Isn't the answer to the second question no, unless excluding severance passed the 414(s) ratio test?
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