Short Plan Year and Imputed Disparity

Company started in July 2018. For a calendar year plan, we will have a 01/01/2018 effective date. Do we have to pro-rate the TWB if using imputed disparity to pass the general test?

I'm answering without the ability to confirm since I'm out of the country.  With that adviso, if the plan is effective 1/1 and the plan year is a 12 month period, then why would you prorate anything?  My answer is NO.

Correct.  It's a full 12  months.  "IF" the plan year was actually shorter than 12 months, then you would prorate the integration level (typically, but not always the TWB).  These types of terms are typically explained in your Plan's Document.

Good Luck!

Is imputed disparity the same as permitted disparity?

If so, I thought that permitted disparity was a design based SH, so why would it be subject to general testing?

4 hours ago, 401_noob said:

Is imputed disparity the same as permitted disparity?

If so, I thought that permitted disparity was a design based SH, so why would it be subject to general testing?

No, they are not.  Check the Erisa Outline Book for the specifics.

7 hours ago, 401_noob said:

Is imputed disparity the same as permitted disparity?

If so, I thought that permitted disparity was a design based SH, so why would it be subject to general testing?

I misread the question.