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Corp. ABC sponsors a 401(k) Plan. Corp. ABC has two 50/50 shareholders who liquidate the business 6/30/14 and go their seperate ways. One shareholder takes 7 of 11 participants to a new corp. which does not sponsor a new plan. This group is treated as terminating from ABC corp. and is paid out in 2015.

The second shareholder takes the other 4 participants to a new corp XYZ which adopts the existing ABC corp Plan as the new Plan Sposnor.

Since ABC and XYZ are not a controlled group or ASG, how must the prior year ADP test be completed?

I have tested the ABC employees separately for the first half of the year and they pass based on the prior year NHCE ADP. If I test the XYZ employees seperately for the second half of the year, what NHCE ratio do I use?

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