If a participant in a multiemployer 401(k) earns $45,000 from two diff

[KJohnson]

It seems 414(q) sends you back to the 415 compensation definition and the 415 regs state that you only aggregate compensation if an employee works for members of a controlled group or affilated service group. Also for purposes of 415 limits, the "default" option for multiemployer plans is to disaggregate employers if an employee works for more than one employer. [1.415-1(e)(2)]

On the other hand, most multiemployer plans "aggregate" all employers and bargaining units for purposes of running the ADP test. If you aggregate employers for purposes of defining the Plan to be tested must you aggregate compensation from employers for purposes of identifying HCEs?