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Posted

A client's DB plan defines compensation for benefit accrual purposes as "total salary or wages, excluding allowances and expense reimbursements." First question: Does that fall under a safe harbor definition?

Second question: If it is a safe harbor, would it remain a safe harbor if the definition were amended to exclude severance pay?

Posted

I think the answer to both questions is Yes. check IRS regs. under 1.414(s).

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

  • 4 years later...
Posted

Just stumbled upon this while doing a search related to treatment of severance for testing purposes. Isn't the answer to the second question no, unless excluding severance passed the 414(s) ratio test?

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