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Posted

If the plan document defines comp as gross W2, can the ADP test be run using net W2 (so that deferrals aren't included in comp)? Is this a discretionary option that can be decided each year, or does it have to be hardwired into the plan document?

Posted

Most docs have it as an option in a pre-approved plan. Yes, it must be authorized in the plan, even if it is done so indirectly with a provision that says something like: "ADP test may be run on any basis allowed by regulations."

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