Annual Additions

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Governmental 457(b) plans are not subject to 415©(1)(A) defined contribution limitation. Governmental 401(a) plans are subject to the limitation. For the governmental 401(a) limits test do you include deferrals made to the employer's 457(b) plan? I don't think so. Can you please provide a site.


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No, you do not. Treas. Reg. § 1.415©-1(a)(2)(i) specifies which contributions to defined contribution plan are treated as "annual additions" subject to 415©. They include only contributions to:

(A) A plan described in section 401(a) which includes a trust which is exempt from tax under section 501(a);
(B) An annuity plan described in section 403(a); or
© A simplified employee pension described in section 408(k).

Thus, a contribution to a 457(b) plan is not part of annual additions for purposes of section 415©.

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