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Posted

I have a plan that needs 414s testing.  For coverage purposes the plan is run disaggregated (applying the under 21/1 yos tested separately), for 414s, do I need to run the test disaggregated?

Posted

As long as the compensation definition is the same for everyone, you can run it either separately or for the plan as a whole. 

Quote

1.414(s)-1(d)(3)(iii) Employees taken into account—(A) General rule. In applying the requirement of this paragraph (d)(3), the employees taken into account are the same employees taken into account in satisfying the requirements of the applicable provision for the determination period. For example, in determining whether a plan satisfies section 401(a)(4), an alternative definition must satisfy this paragraph (d)(3) taking into account all employees who benefit under the plan for the plan year (within the meaning of §1.410(b)-3(a)). If an employer is using the same alternative definition of compensation to determine whether more than one separate plan satisfies section 401(a)(4), the employer is permitted to take into account all the employees who benefit under all of those plans for the plan year in determining whether the alternative definition of compensation being used satisfies this paragraph (d)(3).

 

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