Different Compensation for Different Sources

We have a plan that has different eligibility for deferral and Profit Sharing Sources. The compensation for both is defined from date of entry. Let's say a participant becomes eligible for deferrals on 1/1/2019 and for the profit sharing source on 7/1/2019.

Let's say the compensation from 1/1/2019 to the end of the year is $100,000 and from 7/1/2019 to the end of the year is $50,000. The company allocates 5% to this participant for a Profit Sharing Contribution, so the participant receives $50,000 * .05 = $2,500. However, when performing the General Test, is it the $100,000 compensation that's used or the $50,000?

The DATAIR documents have a separate definition of compensation for "Plan Compensation (including for Elective Deferral purposes)" and "Compensation for Non-Elective Contributions" and I'm wondering if Plan Compensation means that it's the compensation used for all testing (including General Test).

Thanks.

Testing Compensation would not typically be defined in the plan document. In general you are free to use any definition of comp that satisfies 414(s) for testing purposes.

The ABPT is going to include all sources, and the definition of pay for the 401(k) is the whole year's worth, though.

(But hmmm, if you're able to pass all the rate groups at 70%, might you be able to justify doing that only on post-source earnings?) 

For purposes of the ABPT I would agree that if you are excluding pre-entry comp, then "entry" would have to be the earliest date of participation in any part of the plan.