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Posted

When a controlled group wants to give different (discretionary) matching contributions to different companies, what testing is required? One resource is telling me that so long as each company passes coverage and ACP, and the combined group passes, that's all you have to do. Another resource is telling me that you also have to do 401(a)(4) testing.

Does the answer change if they are separate plans for each company rather than all participating in a single plan?

Posted

Different plans need only pass coverage. If you're passing coverae without aggregationg then yoiu run separate ACP tests for each plan and you can ignore the fact that the formulas are different.

If you have one Plan, but different matches for different groups, now you have to test Benefits Rights and Features under (a)(4). Essentially you run a coverage test for each match formula and only you use the nondiscriminatory classification threshholds, instead of 70%. Of course, one Plan = 1 ACP Test, always (not counting otherwise excludable options).

Austin Powers, CPA, QPA, ERPA

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