Guest quinn the car fixer Posted December 1, 2004 Share Posted December 1, 2004 Can you use the age 65 APR for an ee who is over age 65? His APR is lower and that then increases his ebar. I know i can override the age in census to get the APR for age 65. Link to comment Share on other sites More sharing options...
Tom Poje Posted December 1, 2004 Share Posted December 1, 2004 the regs 1.401(a)(4)-12 "testing age": 1. if all have same uniform ret age, then use normal ret age (note 65 and 5 is considered uniform) 2. if different ret ages for diff groups, use the latest ret age 3. if not uniform use age 65 (this can happen if you have something like plan val date nearest) 4. if beyond testing age, the employees testing age is the employees current age. (There is an exception if the plan is a defined benefit) but if it is a DC plan I dont see how you can use APR other than current age, as indicated in #4 Link to comment Share on other sites More sharing options...
Guest DFerrare Posted December 1, 2004 Share Posted December 1, 2004 Tom, If you are cross-testing a DC plan can't you use -8(b)(1)(ii) to ignore the current age rule? Link to comment Share on other sites More sharing options...
Tom Poje Posted December 1, 2004 Share Posted December 1, 2004 possibly, it is unclear from the original question if that would apply in this case. the particular reg cited is applicable if allocations are made at the same rate for someone who is past NRD as someone who is at age 65. (age weighted plans are often written to provide the same rate for someone who is past NRD as someone who is at NRD.) I guess technically this doesn't really mean you use APR at 65 for someone who is past age 65, but rather those people won't cause the plan to fail if they receive the same rate. I suppose if you needed 'proof' the plan passes you would 'fake the system out' using the same APR Link to comment Share on other sites More sharing options...
Guest quinn the car fixer Posted December 1, 2004 Share Posted December 1, 2004 it is a ctp and the allocation would be the same pre / post age 65 Link to comment Share on other sites More sharing options...
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