DLMRetire Posted December 6, 2013 Posted December 6, 2013 Controlled Group consisting of 2 entities. One entity "M" declares a match , the other entity "NM" does not for a particular year. If employee A earns wages from "M" and "NM" and defers off of wages from both "M" and "NM", do we need to use deferrals and wages from "NM" when figuring out the amount of match "M" owes? Is it possible to word each document to exclude such wages and deferrals from the other entity when calculating the match? Understand that combined testing ADP/ACP required.
Lou S. Posted December 7, 2013 Posted December 7, 2013 How is compensation defined for allocation purposes in the Plan document? Are these 2 separate plans each only adopted by one of the CG members or one plan with two divisions?
DLMRetire Posted December 8, 2013 Author Posted December 8, 2013 It is not yet set up so question somewhat of a hypothetical. So if we had one plan adopted by each member of controlled group but one employer matches and other does not (ie document written so each employer has discretionary match each year) and we define compensation as paid by employer (meaning both employers) can we limit match each pay period to only comp and deferrals paid by respective employer who is making such match? Definately understand there could be 414s testing and nondiscrim testing issues.
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