21 & 1 with semi-annual entry
3% Safe Harbor using entry date comp
New Comp PS allocation, entry date comp, HCE’s receiving >15% of comp.
Plan is Top Heavy
NHCE Participant A hired 3/1/2014 and worked over 1,000 hours in first 12 months. A's work schedule changed to “as needed” 4/1/2015. Employed on 7/1/2015, and entered the plan 7/1/2015. Still employed beyond 12/31/2015, but no compensation during 7/1/2015-12/31/2015. A has $6,000 of compensation in 2015, all of it prior to 7/1/2015 and receives $180 of PS as a TH minimum since she is a participant and employed on the last day of the plan year.
Anyone had this situation come up before? If so, what did you do for gateway and (a)(4) testing?