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I have a plan document that uses "Code Section 415 Safe-Harbor Compensation" definition which reads like (but does not reference) the general definition under 1.415-2(d). The company does not calculate deferrals on imputed income amounts for group term life and personal car usage. The plan document does say that Compensation shall include amounts received: “… for personal services actually rendered in the course of Employment…” and at the end it says “… Compensation shall include only that Compensation which is actually paid or made available in gross income during the Limitation year”. Do either of these provide a reasonalbe basis for not including these amounts in calculating contributions?

PAL

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