So I'm a pretty junior tpa (I've been doing this for about 3 years) and while I've learned *a lot* I recognize that there are things (probably many of them) that I still don't know. This is one of those things.
So I was asked to do a profit sharing calculation on a plan that is just starting up, it's a calendar plan year with the first year being 2019. This plan has fairly average eligibility rules all around (18, 1 yos (1,000hrs), dual entry) but the business was not started until 7/6/2018 so not surprisingly most everyone won't be eligible until 1/1/2020.
Now the way the census is looking the two owners have a DoH of 7/6/18 and most everyone else has a DoH of 7/20/18.
Here's where my question arises. I was asked to write in a waiver of eligibility for the Profit Sharing source for employees employed on 7/6/18, which obviously will only be the owners. Meaning they'll be able to receive a profit sharing in 2019 and everyone else will have to wait until 2020 when they're eligible This should pass testing as well (it's a fixed class based pro-rata) as long as the owners stay under 25% of the payroll. Now I suspect this is likely perfectly fine, but it sorta "feels" discriminatory in favor of the owners in terms of the waiver of eligibility... so just wondering if this is something that should maybe be questioned or not? Either way I appreciate everyone's feedback and for taking the time to read this.