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I need confirmation on HCE determination and testing. Company was started in 2009, then was purchased by equity firm which caused a plan term (no assets transferred). Company was an adopting employer on the new plan. Company was then sold as a spin off and they are no longer related to equity firm and they created a new plan and no assets were transferred and the participants had the option to roll funds over to the new plan from the prior plan. This company had the same EIN the whole time. Does this make a difference in testing/HCE determination?

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