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I am working with a company that set up a Premium-only plan for 2000. The plan is "semi-self insured", in that the insurance company charges a fixed premium per month, and then a variable portion, which is attributable to individuals within the plan.

In terms of administering the 25% Key Employee concentration test for the year, what premiums are counted towards the total which is then used to calculate the 25%? Is it fixed premiums, or the total premiums? Doesn't this make testing diffucult, as the number is a moving target? What happens in a year when the variable portion is attributable mainly to one of the key employees? (My company has 6 brothers who each own 16.67% of a C-corp)

Any ideas would be appreciated. Thanks!

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