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JustMe

Aggregation of Different Plan Years due to plan termination

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I have a DC plan with a 12/31 PYE and a terminating DB combo plan associated with the same employer. I know plans of the same employer with different plan years may be aggregated for ABT testing purposes under 1.410(b)-7(e), but do you just follow the rules of 1.410(b)-5(d)(5)(ii) and add the DC contributions divided by calendar year compensation to DB benefits divided by partial year compensation? Is it that easy or am I missing something? Any different rules when the plan is a short plan year versus just a different plan year? 

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8 minutes ago, JustMe said:

I have a DC plan with a 12/31 PYE and a terminating DB combo plan associated with the same employer. I know plans of the same employer with different plan years may be aggregated for ABT testing purposes under 1.410(b)-7(e), but do you just follow the rules of 1.410(b)-5(d)(5)(ii) and add the DC contributions divided by calendar year compensation to DB benefits divided by partial year compensation? Is it that easy or am I missing something? Any different rules when the plan is a short plan year versus just a different plan year? 

It is even easier. Just ignore the plan termination. Continue to aggregate. Be happy.

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By ignore the plan termination, do I use full year compensation for both plans? 

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Yes.

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