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ASPPA Announces Reversal of IRS Position on Combined Plan Limit; Consider Additional Contributions Today or Tomorrow (Sept. 15)
American Society of Pension Professionals & Actuaries [ASPPA] 
Sept. 14, 2007
Excerpt: Q&A 9 of Notice 2007-28 will not be enforced and, in a defined benefit/defined contribution plan combination situation, if the DC contribution was not greater than 6%, Code §404(a)(7) does not apply to the defined benefit plan. This is effective for the 2006 plan year and has two primary IMMEDIATE effects: Employers who contributed in excess of 25% of compensation to their defined benefit plan (and in excess of Unfunded Current Liability) in 2006 based on an interpretation in conflict with Q&A 9 of Notice 2007-28 need not pay an excise tax; and employers who move fast for 2006 (who were previously limited by Notice 2007-28), have until tomorrow to increase their 2006 deductible contribution.
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