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Posted

Plan definition of pay is 3401(a) wages, excludes excess GTL, ALL fringe benefits, expense allowances, etc and commissions.

We need to run a 414(s) test due to the commission exclusion.  When calculating each participant's compensation percentage, I will put commissions in the numerator but what is in the denominator?  Specifically, must the denominator include the excess GTL and fringe benefits or can those be excluded from the denominator?  I am thinking I would exclude them since they are not part of plan compensation and  are allowable safe harbor compensation adjustments.  Is that correct?  Thanks! 

Posted

your opening comment said you would out commissions in the numerator

yet if commissions are excluded that should be the one spot you don't put them in, only in the denominator.

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