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Posted

Deferrals/SH: age 21, 2 months, quarterly entry

PSC: age 21, 1 YOS, Immediate entry

both SH and PSC exclude pre-entry compensation

if an employee who became eligible for def/SH on 7/1/2024 with a pre-entry compensation. since he is entitled to SH, then he needs to get GW min. we use 5% GW test method which allows us exclude pre-entry compensation. can I use the SH post entry compensation for GW min calculation in this case? or we have to use full year compensation for GW since the post entry comp is for SH but not PSC?

 

thanks in advance

Posted

Are you using the option to disaggregate otherwise excludable employees from testing? If so, the employees who haven't met 1 year of service (i.e. those who aren't eligible for profit sharing contributions) wouldn't need to receive the gateway minimum.

In general, the definition of compensation used for allocations does not dictate the definition of compensation used for testing. You can use any allowable definition of compensation for testing.

Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance.

Corey B. Zeller, MSEA, CPC, QPA, QKA
Preferred Pension Planning Corp.
corey@pppc.co

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