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New CB and 401(k) with short plan year


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The Employer terminated a Cash Balance Plan and 401(k) Plan 2020.   The last distribution in the 401(k) Plan was June 1, 2020.   Will start new plans effective 6/1/2021 with short plan years from 6/1/21-12/31/21.  Looking for confirmation:

1. Cash Balance participants will earn full Contribution Credit for 2021.   Cash Balance TNC for both minimum and deduction is not prorated and essentially is the same if the Plan was effective 1/1/2021?

2. The maximum annual addition for the 401(k) Plan is prorated for the 7 month plan year.

3.  The maximum Compensation used for allocations is prorated for the short plan year.

4.  Nondiscrimination testing Compensation can be average of 3 full calendar years?   So the Employer Contributions to the 401(k) Plan could be allocated on Compensation after 6/1/2021 but testing is annual Compensation?

 

Thank you.

 

 

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