NW529 Posted January 7, 2021 Share Posted January 7, 2021 A plan is effective for the first time on 8/1/2020. When determining Key status for Officers and greater than 1% owners for the initial plan year, what compensation is used? 1/1/2020 - 12/31/2020, or 8/1/2020 - 12/31/2020? Link to comment Share on other sites More sharing options...
CuseFan Posted January 7, 2021 Share Posted January 7, 2021 Looking at language in a pre-approved document, it says annual 415 compensation, so I would say you need to look at the entire year, but you should check the 416 regulations for certainty. Luke Bailey 1 Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com Link to comment Share on other sites More sharing options...
FORMER ESQ. Posted January 7, 2021 Share Posted January 7, 2021 2 hours ago, NW529 said: A plan is effective for the first time on 8/1/2020. When determining Key status for Officers and greater than 1% owners for the initial plan year, what compensation is used? 1/1/2020 - 12/31/2020, or 8/1/2020 - 12/31/2020? The 1.416 Treasury Regulations require you to use 415 annual compensation-- 1/1/2020 to 12/31/2020. Luke Bailey 1 Link to comment Share on other sites More sharing options...
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