AKconsult Posted September 7, 2018 Posted September 7, 2018 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!
CuseFan Posted September 7, 2018 Posted September 7, 2018 That is my understanding, your denominator just needs to be a safe harbor definition amount, whether 3401(a), W-2 or 415(c) with or without permissible exclusions. Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
Tom Poje Posted September 10, 2018 Posted September 10, 2018 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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