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Executive spends 6 months in US an 6 months in foreign country.  Paid for part of the year in each country.  US comp is just under $130,000.  If  the Chinese comp for the work done in China counts towards being an HCE, then he would be an HCE.

Does it count?  My definition of comp for 415 is w-2 wages...

Austin Powers, CPA, QPA, ERPA

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