"If an employee receives a benefit that is includible in taxable wages, then it needs to be included in compensation for plan purposes ... [W]here the benefit is an object or a gift card, or other tangible item ... the employer will need to impute (attribute) income to the employee and make deferrals from the liquid cash compensation in an amount that considers the non-liquid compensation imputed to the employee. Employers may want to review whether these items of compensation can be eliminated or restructured to meet the de minimis fringe benefit exclusion."  MORE >>