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I am starting a new thread because I think it it warranted and better suited in the 401(k) message board. 

Please see my prior question and the replies from @Larry Starr and @Bill Presson

I'd like to clarify upfront that I am NOT asking about the start-up cost credit. I think I have a pretty good handle on that one. I am asking about the NEW! automatic enrollment credit provided by SECURE. Please don't conflate the two. 

 

Question: Section 45T that adds the new EACA credit. Can a one-person plan (HCE only) claim this credit? Assuming of course they are amending their plan to add an EACA? 

I don't think the plan start-up costs definition in 45E is relevant because this isn't a plan start up cost. 

Does anyone think the sponsor of a 1 person HCE plan CAN'T claim the credit? If so, why? 

I'm a stranger on the internet. Nothing I write is tax or legal advice. 

I'd like a witty saying here, but I don't have any. When in doubt, what does the plan document say?

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