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Severance pay used in testing


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Guest Peggy806
Posted

Our document does not allow deferrals to be made on severance pay, per the 415 amendment. When we do the testing, do we include the severance pay in ADP testing, in calculation of a 3% NEC, in calculation of a match, etc., etc or do we exclude the severance pay from all the calculations?

Posted

My understanding is that true severance pay is never considered compensation for plan purposes. You can check out the Compensation Glossary in the ERISA outline book -- it does a nice job of breaking down the components for W-2, 3401(a), Safe Harbor 415 and 415 comp -- you'll also have to check your document to make sure those base definitions don't have any additional exclusions/inclusions.

My copy that I have on hand excludes severance pay from all four base definitions.

Posted

Are you confusing "severance pay" with "compensation paid after severance of employment."?

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

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