Sch. T - collective bargained and NHCE's in same plan.

[Guest]

I am doing a 5500 Schedule T for a plan which is made up of 50% collectively bargained employees (all NHCEs) and 50% non-highly compensated employees. Should I check both 3(B) and 3© or just 3(B) or file two Schedule T's (one for collective bargained piece and one for the NHCE's).

I'm leaning towards checking only 3(B), although I don't think this is technically correct since the collective bargained piece should be disaggregated from the non-collectively bargained piece, but I don't see anything in the instructions telling me that I have to do two Schedule T's.

Any one have any ideas?

[Guest]

while I agree the 'parts' normally need to be disaggregated, since there are no HCEs benefiting, it doesn't matter. the govt appears to be only interested if you are favoring HCEs. that is the purpose of part 4, but you never get there, so it shouldn't matter. (You can discriminate amongst the NHCEs all you want)

I wouldn't check 3c (unless they were indeed the only ones who benefitted. I can't tell from your note.

of course I could be wrong, but that is the way I read it.

see also instruction line 4c 4 'disaggregate because it BENEFITS BOTH collective / noncollective ees.

you either 1. aren't benefiting both or

2. benefiting both, but since no hces the pass automatically passes anyway.