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An employer uses a PEO for HR outsourcing, all employees are leased employees. Leased employees participate in the PEO 401(k) plan. The employer wishes to add a Defined Benefit Plan which would provide maximum benefits to the owners and the minimum meaningful benefit to all other employees.

If the employer sponsors the DB plan, can this plan be aggregated with the PEO 401(k) plan for 401(a)(4) testing?

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