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Agenda
Controlled Group Issues Plan Aggregation Issues Determination of HCEs Determination of Most Valuable Accrual Rates
Groups to Include
Who knows the group? Are there leased employees? Are there affiliated service group relations? Are there acquisitions?
0%-Svcs only
USA
USA
B
80% USA
France
100%
H
50%
Canada
C
40%
-acquired prior year
D
40%
USA
USA
50%
85%
0%-Leasing grp
France Exercise: Identify controlled groups in years 0, 1, and 2, assuming acquisitions admitted to controlled group at end of transition period 6
USA
USA
After reviewing a leased employee checklist, Who Me Lease calls back with 200 leased employees
since the controlled group had only 2000 NHCEs before, the 75% ratio test changes to 68% and now requires an average benefit percentage test
10
After transition, All Together Now attorney gets involved in testing and determines there is a single employer, not multiple employers
17
Groups to Exclude
Are there multiple employer plans? Are there joint ventures? What about the taxexempt exclusion?
18
19
22
23
No divisions 401(k) plan covers 95% of Well Take It employees to exclude tax-exempts
25
29
32
Determining HCEs
40
42
44