We administer a plan that was amended from a 12/31 year end to a 6/30 year end, creating a short plan year from 1/1/2020 to 6/30/2020.
The limitation year is the plan year.
The plan has an Officer (not previously a key employee) who has compensation of $93,000 for the 6 month short plan year ending 6/30/2020.
Regarding the top heavy test and key employee determination (Officer Test) for a short plan year. From what I've found in the EOB, it indicates that while there is not specific regulatory guidance, it would be reasonable to either prorate the compensation test for the short period, or it would also be reasonable to annualize an employee’s actual compensation for the 6 month plan year.
Curious to what others may have done or would do in this scenario for key determination.
Thank you.
