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Posted

HCE terminated employment 12/31/2002 but had compensation and hours in 2003 due to payout of vaction time with $0.00 deferrals. Do I include him in my 2003 ADP as a HCE with a 0% deferral rate?

Posted

The regulations permit you to do it either way as long as you do the same for all employees under similar situations. See 1.415-2(d)(5)(ii)

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