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otherwise excludables and gateway


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Suppose you have a typical db/dc combo but with the db 21 and 1 and the 401(K)/profit sharing immediate entry across the board. The two plans are a required aggregation group that is top heavy..Do the general rules that not allow you to restructure to avoid the gateway apply even if the restructuring is only to carve out the otherwise excludables….?  

 

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3 hours ago, John Feldt ERPA CPC QPA said:

But you may be able to use the OEE rule to avoid gateway for those under 21/1.

Isn't that what was already said?

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