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Posted

Am I correct in assuming that if employees are excluded from participation by class, they get neither the top heavy minimum nor the gateway? Also, if there is no exclusion by class, it is OK to give non-key HCEs just the top heavy minimum, not the gateway? Thanks.

Posted

Yes. No. Anyone non-statutorily nonexcludable NHCE participant benefiting via a nonelective contribution in a plan that is cross-tested must receive the gateway (document notwithstanding of course). That is why a top heavy contribution, a QNEC or a safe harbor nonelective contribution can cause an otherwise smaller contribution to need to be increased to the minimum gateway amount.

Oops, I re-read your post and you said non-key HCE. You are correct.

"What's in the big salad?"

"Big lettuce, big carrots, tomatoes like volleyballs."

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