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Am I a key employee?

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Plan is calendar 2020.

5%+ owner terminates in April 2020 and sells his ownership to the other shareholder.

Under HCE, because he was an HCE on 1/1/2020, he is HCE for 2020.

How key employee rules, are the same here i.e. he is a key for 2020 because he was on 1/1/2020?

Thank you

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