Similar question as the previous one by KJohnson. This one is on HCE d

[AndyT]

I realize this section is for "multiemployer" plans as opposed to "multiple employer," but I thought my question might pertain to the former as well.

SCENARIO 1: Companies A and B have adopted the same plan; they are unrelated employers. Employee X makes $50,000 for each company. X is not an HCE for either company, correct?

SCENARIO 2: Same facts as above - Employee Y owns 10% of A and 0% of B. Y is an HCE for A, but a non-HCE for B, correct?

SCENARIO 3: Same facts as above - Employee Z earns $100,000 from A and $0 from B. However, Z performs services for B, and B reimburses A $50,000 for those services. Is Z an HCE for A and B, or just for A?

Any insight would be much appreciated.

------------------

Andy Treece