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Posted

For determining 415 compensation, are any of the following included:

Car income

car allowance

severance

group term life insurance income

Am I correct that possibly in addition to the above and barring barring any other "unusual" forms of compensation, 415 comp is basically W-2 plus elective deferrals?

Posted

You basically have three definitions of 415 comp (Current Includible Comp, W-2, Wage Withholding Comp,) some of these items are includible in one definition and may be excludable from the other (i.e. Term Life Premiums might be on W-2 and in CIC but not on 3401(a).) As far as the Car Allowance, it depends if it is taxable or not.

Severance should be in all three.

To make things simpler, you can modify the 415 definition in your plan by excluding certain items like Fringe benefits, Reimbursement/expense allowance, Moving expenses, Deferred compensation, Welfare benefits. If you choose to modify your definition of 415, you have to exclude all these items or none.

/JPQ

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