fiona1 Posted April 20, 2004 Posted April 20, 2004 I'm trying to determine who is Highly Compensated but I'm unclear what pay I'm supposed to use. It's a new plan that was effective in June of 2003. The company was sold in June and the new owners started this DB plan. The employees worked for the whole year in 2003 - but for part of the year they were working for the prior owners. Do I use their compensation for the whole year in determing if they are Highly Compensated for 2004? Or do I just use the pay they made under the new owners?
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