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Gateway Minimum in a Top Heavy Plan with Participation Compensation


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Posted

I have a Top Heavy Safe Harbor/Cross Tested Plan.

Compensation for plan purposes is participation compensation.  Obviously, the Top Heavy Minimum must use the entire year's compensation.

Must the Gateway therefore be based on the entire year's compensation?

 

Posted

A plan is permitted to use partial year compensation for Gateway purposes, assuming the comp definition otherwise satisfies all requirements.

1.401(a)(4)-8(b)(1)(vi)(B)

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