Karen McIver Posted November 20, 2018 Share Posted November 20, 2018 If the plan document states that everyone is in their own group and the contribution is allocated prorate or on an integrated basis do you still have to pass the average benefits test? Link to comment Share on other sites More sharing options...
Tom Poje Posted November 21, 2018 Share Posted November 21, 2018 you could test on an allocation basis, and impute disparity and you would pass testing as all should have the same e-bar (assuming you don't have 30% NHCE that receive nothing because last day rule or something like that.) plus, no gateway since tested on allocation basis Link to comment Share on other sites More sharing options...
Luke Bailey Posted November 21, 2018 Share Posted November 21, 2018 Karen Mciver, is what you are asking whether you can restructure the plan for testing purposes under 1.401(a)(4)-9(c) into the component plans, i.e. the component plan with the comp to comp allocation and the component plan with the integrated allocation? If each component satisfies ratio percentage, you would not need to satisfy average benefits. Luke Bailey Senior Counsel Clark Hill PLC 214-651-4572 (O) | LBailey@clarkhill.com 2600 Dallas Parkway Suite 600 Frisco, TX 75034 Link to comment Share on other sites More sharing options...
Karen McIver Posted December 3, 2018 Author Share Posted December 3, 2018 Thank you Link to comment Share on other sites More sharing options...
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