"When running the Contributions & Benefits test, are all pretax contributions (Ins. premiums, HSA, FSA, DCA, LPFSA) added together and then a test is run of the HCEs vs. the NHCEs, or is a shorter list of contribution types used?"

"My client that is sponsoring a defined benefit plan is considering an acquisition of another business. In scenario 1 the purchaser makes 100% cash deal and pays $3,000,000. In scenario II the purchaser pays $500,000 and covers all employees of the acquired company in the DB plan granting past service back to original date of hire with the seller. Lets assume that the value of the accrued benefits one day after the deal is $2,500,000. How does the Scenario II impact the taxation from both the buyer and the seller perspective? How is the Form 8594 prepared to report the transaction? Are there any other considerations? All the coverage, non-discrim, participations, etc. issues before and after the transaction are non-issue."