Comp for HPI question: change in sponsor

[BG5150]

2025 plan was sponsored by partnership (taxed as one) January to October.  Jane and Wayne Company, LLC.

In November, Wayne left, new company Jane, Inc., an s-corp, is new plan sponsor, new tax id.

For my 2026 HPIs, do I consider the entirety of 2025 or just Nov & Dec, the months the current Employer was sponsoring the plan?

I am using full 2025 comp for my 2025 testing because only the 

[Dare Johnson]

The final regulations addressed this:

(i) A catch-up eligible participant's wages for the calendar year preceding the calendar year in which the taxable year begins from one employer sponsoring the plan are not aggregated with the wages from another employer sponsoring the plan for purposes of determining whether the participant's wages for that preceding calendar year exceeded the Roth catch-up wage threshold in paragraph (a)(2) of this section; 

[CuseFan]

Also, I thought for HPI it is only W2 income that is considered, so sole props and partners aren't subject to that - so you only look at Jane's W2 income for those 2 months. Or am I thinking about something else?

[BG5150]

I'm not considering Jane.  And it's W2 Box 3 income.

Per the regs, it's compensation from the 'employer sponsoring the plan'.  So I'm only using comp while Jane sponsored the plan in 2025 for the HPI calc.