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"easy" eligibility question crossing the plan year


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Calendar year plan, employee is hired during the last week of 2019.  However, the first paycheck they receive isn't until the first week of 2020 (and counts on the 2020 W-2).  Does the universal availability clause require that the participant be counted as a participant in 2019, even though there is no official 2019 compensation?  And this plan has an ACP Test - I would say that the participant had no opportunity to receive a match and therefore can't be counted in the 2019 ACP Test... but I would have to include them in a coverage test.  I don't really have a basis for that (yet), but it seems ridiculous to include someone in a test that they had no opportunity to take advantage of (hmm, so then why include them in 410(b) testing?).  Any sage advice?  Thanks.

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