msmith Posted February 5, 2019 Posted February 5, 2019 A plan excludes bonuses in the definition of compensation. If the plan can pass 414(s) testing, I know I can include the bonuses to calculate the ADP's. My question is, can this change from plan year to plan year (i.e. one year include bonuses in ADP testing, the next year exclude bonuses in ADP testing)?
msmith Posted February 5, 2019 Author Posted February 5, 2019 I should add that the document is silent in this regard, except for stating that 414(s) compensation must be applied uniformly to all participants for the plan year.
Tom Poje Posted February 5, 2019 Posted February 5, 2019 since you are permitted to use any definition that would satisfy 414(s) then it would seem you could switch year to year. the only precaution is if using prior year testing you would have to rerun your prior year test to make sure your definition of comp for each year are the same
msmith Posted February 5, 2019 Author Posted February 5, 2019 Thank you, Tom. It is prior year and I did go back and change the NHCE's ADR's.
BG5150 Posted February 6, 2019 Posted February 6, 2019 On 2/5/2019 at 7:45 AM, Tom Poje said: since you are permitted to use any definition that would satisfy 414(s) then it would seem you could switch year to year. the only precaution is if using prior year testing you would have to rerun your prior year test to make sure your definition of comp for each year are the same Is that true in all cases? I have a adoption that has a separate place that indicates what comp is included/excluded for ADP/ACP tests. If it says nothing is excluded, would that mean I would HAVE to test with them included, even though the rules say I don't? QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
Tom Poje Posted February 6, 2019 Posted February 6, 2019 you are correct, you could have a document that 'requires' something most I have seen simply say 'any definition that satisfies 414s sort of like cross testing, I think we have one document that specifies interest rate and mortlity table
BG5150 Posted February 6, 2019 Posted February 6, 2019 1 hour ago, Tom Poje said: you are correct, you could have a document that 'requires' something most I have seen simply say 'any definition that satisfies 414s sort of like cross testing, I think we have one document that specifies interest rate and mortlity table Tom, most docs I've seen give you latitude when it comes to testing comp. This is the first doc that I've seen that states it. QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
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