"The wage threshold is based on Social Security (FICA) wages paid to the individual by the employer sponsoring the plan.... The threshold is not prorated ... It also appears as if partners in partnerships or other self-employed individuals will not be subject to this provision if they do not have FICA wages.... [T]he guidance does not address whether ... 'super catch-up' contributions are required across controlled groups if implemented by a single employer in the group."  MORE >>