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Change in Ownership during an aquisition causes AFG situation - What can the one HCE/owner do outside the plan to avoid coverage issue


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Coming to the experts.  Need to avoid coverage issues for my new AFG.  One 20% owner participates in the plan that my firm administers.  Originally I thought non-qualified outside the as our ERISA counsel suggested.  This is an LLC though taxes as Sub S I believe.  I'm now being told not going to work if they want the current tax deduction.  What are my options for this one employee to avoid the coverage issue for tax deferred savings?  

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