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Found 3 results

  1. Can SEP contributions be permissively aggregated for purposes of cross testing? I.e., Average Benefit Percentage Test, Average Benefit Test, and Gateway Minimum? The plan sponsor has both a SEP and a profit sharing plan in 2020 and the SEP is on an approved individually designed document. Thank you in advance.
  2. Hi all! The answer to this may be black and white and I apologize in advance if it has been asked before (I did my due diligence searching for the answer on here prior to posting) Basic info: 1 HCE, 13 NHCEs, multiple contrib allocation groups all of which get a contribution (no zeros), last day employment requirement so all terminees didn't get an allocation Plan passes ABPT but fails 410(b) ratio percentage at 60%. I understand that the plan can pass coverage with ABPT only, given "Reasonable Classification" was utilized in assigning allocation groups. Given the following excerpt, I would say it's okay to skip the 410(b), however one issue is not clear to me: Is giving a zero allocation to terminees due to the last day employment provision of the plan, not make a "Reasonable Classification" thus requiring us to pass the ratio test?? Thank you.
  3. Our parent company recently purchased another company. We're testing things to see how we'll pan out with the coverage test. Some of our plans now fail the ratio test (using the entire controlled group) so we're moving to the ABT. As part of the ABPT on a stand-alone basis (no permissive aggregation yet), we need help with determining the denominator for each plan. Plan A NHCE avg benefit rate: 9% HCE avg benefit rate: 10% (1000 NHCEs and 200 HCEs) Plan B NHCE avg benefit rate: 4% HCE avg benefit rate: 4.5% (300 NHCEs and 50 HCEs) Aggregate NHCE avg benefit rate: 7.85% HCE avg benefit rate: 7.25% Do the results for Plan B come out as 88.9% (ie 4/4.5) or as 55.2% (4/7.25)? Thanks.
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