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The plan is a multiple employer plan with 2 employers.  The employers are related, BUT not enough to be a control group or ASG (attorney has already opined on this).  One person owns 99% of company A which is a partnership and a small % of company B, which is a Corporation.  He receives compensation from both entities.  Both entities offer a basic safe harbor match, no other employer contributions.

Can this person split his deferrals between the 2 entities and get a full match from each entity?  I am going back and forth on this.  Because both entities are in the same plan (even though it is a multiple employer plan) do we would have to combine his pay and calculate just 1 match?  I read that there is one combined 415 limit, but what if the owner received $285,000 in pay from each entity and deferred $13,000 from each entity and received $11,400 match from each entity?  He would not be over the 415 limit.  I think this would be OK if each entity had a separate plan, but is there anything about the MEP that would prohibit the full match from each employer?

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