samuel winikor

Hi, Thanks in advance for any and all comments. Does a safe harbor floor offset arrangement in which the two plans are not permissively aggregated, and thus treated as two separate plans, required to have the same plan year for both the DB and DC? In 1.401(a)(4)-8, it doesn't seem to be one of the requirements of a safe harbor design. If not, can I still test the rate groups prior to the offset and the AB% test net of the offset? Thanks, Sam Winikor