401K and SEP maximum contribution

Does anybody remember which past issue(maybe a few years ago) addresses the maximum 415c contribution limits from unrelated jobs to 401k AND SEP ?

I have 1 job which puts me at 415c limits.

I am also a Financial Advisor. With the Financial Advisor I have 2 LLC’s with 2 different Tax ID numbers. 1 source of income is Securities related from my Registered Investment Advisor. The other source of income is from my insurance business.

My Contention is all 3 incomes are unrelated jobs therefore I should be able to contribute or company contributions the max 415 limits to 401K. Also should be able to contribute the max(up to 415c to SEP’s) to the other 2 financial incomes also.

My CPA is telling me the financial incomes do not qualify for the 2 separate $51,000 contribution limits.

Thank you



There are aggregation adn affiliated service group rules under which the two LLCs are considered one employer since you control both of them. The other job would allow a second 415c limit as long as it is a different employer and not aggregated with the LLCs.



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