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Because the plan document specifies a new comp allocation, which is not a safe harbor formula, you have to satisfy the general test (aka the rate group test). However if you calculate your rate groups on allocation rates, instead of on accrual rates, then everyone should be in the same rate group and the test should pass easily. You don't need the gateway because you're not cross-testing. You also don't need the ABPT unless your rate group is less than 70% coverage (which is unlikely to happen, unless, as Lou mentioned, there is an allocation condition that isn't met by a large number of NHCEs).

My understadnign is no. W2 reportinb (Box 1) is completely unchanged. The participant is eligible to claim a deduction on their 1040. Same for overtime. I realize not all plans use the W-2 definition of wages but the same logic applies. This is solely a new deduction for people to claim. it is does not eliminate income.

A § 401(a) retirement plan does not count § 457(b) deferrals in § 415 annual additions. For example, an individual in her early 60s might have 2026 retirement savings like this: (I assume my estimates of inflation-adjusted limits for 2026.) 457(b) deferral $36,500 (salary $40,000 as a retired government employee) 403(b) elective deferral $36,500 (salary $40,000 from a university lectureship) 401(a) nonelective $90,000 (compensation $360,000 as a 50% owner) $163,000 Observe that the § 401(a) plan’s annual additions do not count against the § 403(b) account’s annual-additions limit. 26 C.F.R. § 1.415(f)-1(f)(2)(ii) https://www.ecfr.gov/current/title-26/part-1/section-1.415(f)-1#p-1.415(f)-1(f)(2)(ii). In my experience, many government employees also have other employments and other businesses. This is not advice to anyone.

I am not ashamed to admit I did not make it to page 63 😂😂😂

Look on page 63 of final regs - real clear - good faith until 1/1/2027. Specifical says administrative transition period IS NOT EXTENDED.

Just test it on an allocation basis instead of a benefits one. Everyone will get the same percentage and be in the same rate group. Unless you have a ton of turnover and fail the ration percentage test due to last day requirement or some other odd scenario.

It looks like she was terminated prior to meeting eligibility for the MT and PS so I'd say no she's not. Her 90 days would be 12/22/2024 and entry date 1/1/2025.

Recent thread on this. In short, you must comply with the Roth catch-up requirement in 2026 on a reasonable and good faith basis, and you must comply with the final rule in 2027.

The plan document will indicate whether the top heavy minimum is computed based on years of service or participation.