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DC+CB combo but different compensation definitions


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Cannot think straight on this issue so need to ask.

Sponsor FY is 7/1/2020 to 6/30/2021 and the DC+CB plans are the same period.

Working with a DC person and set up a CB plan for 7/30/2020 year end and did not need to aggregate the plans for testing. For the 6/30/2020 year end, the compensation was FY of the corporation under the CB plan. It just worked.

I just got a copy of the updated document for the DC plan (signed 12/1/2020) and noticed that the compensation is checked as calendar year ending within the FY.

So I have 2 plans to test but 2 different compensation definitions. I must aggregate the plans for this year, do not have a choice.

Any suggestions on what to do? I am trying to have them change the definition of compensation (may also need the HCE determination but this is another story).

How can I test 2 different compensation definition?

Thank you

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Yes, i/o 7/30/2020, it is 6/30/2020.

I understand that you can use different definition for testing but how about 2 different plans by the same sponsor using 2 different compensation periods? Isn't this an issue for deductions?

Anyway, I am having them amend the plan and match the cb plan. I love KISS method.

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