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Rev. Rul. 2003-11 Does Not Address Section 401(a)(26) Additional Participation Requirements
Deloitte & Touche Human Capital Advisory Services 
Feb. 6, 2003
Excerpt: By applying the increased limit to prior years' compensation, benefits can be significantly increased for retirees whose benefits were previously limited by § 401(a)(17). However, the ruling fails to address IRC § 401(a)(26). Therefore, plan amendments that take advantage of Revenue Ruling 2003-11 could violate IRC § 401(a)(26).... [T]he potential impact, if any, of IRC § 401(a)(26) must be analyzed and communicated to employers when plan designs take advantage of the increased limit.
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