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Posted

I'm setting up a 401(k) that initially will have no NHCEs. Down the road, some will be hired and eventually become eligible.

Plan effective calendar 2003. NHCE hired after 7/1/03. Year of service after 7/1/04 eligible 1/1/05.

How is it determined what the maximum deferrals are for the HCEs in 2005? Say the testing method is prior year.

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Posted

Will this plan have HCEs because all of them are 5% owners? If not, is there any chance that you end up with NHCEs due to the top-paid group rule?

Posted

I'm deliberately not using the top 20% rule to include a non-owner over $90,000 as a HCE. The rest are family of the owner (wife, son, daughter), so HCEs by attribution. Interestingly, non-owner is not Key, so 3% TH is an issue.

Owner will be deferring close to 50% of comp and match close to 100% of deferral.

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