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What compensation is used to determine whether or not a person is a HCE?

Example: If a person receives compensation of $60,000 from one employer from Jan 2012-May 2012, then works for another employer from June-Dec 2012 and earns $75,000 all under the same collectively bargained agreement and the same plan document, would they be considered a HCE for 2013?

  • 4 weeks later...
Posted

No, because 414(q) refers to compensation from an "employer" (which means one company and all others in the controlled group or affiliated service group).

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