414(s) compensation test

[Guest H.J.]

For purposes of running a comp test, Reg. 1.414(s)-1(d)(3)(vi) limits an individual employee's compensation percentage to 1.00 for alternative definitions of comp that use rate of compensation or include prior-employer or imputed compensation (that is, the numerator can't be more than the denominator). The instructions to Demo 9 of Sch. Q hint that this limitation is also true for all alternative definitions of comp, but the regs only state the limitation for alternative definitions that use rate of comp or include prior-employer or imputed comp. Does anyone have experience with this issue? For a 414(s) comp test, can the numerator be greater than the denominator in calculating an individual comp percentage?