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415 and 402(g) limits=>participant in both govt&private plans


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Yes. 415 limit is separate for different employers (so long as they aren't part of the same control group). 402(g) is measured at the employee level. 

Employee benefits legal resource site

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On 12/18/2021 at 6:52 PM, John Feldt ERPA CPC QPA said:

And watch out for 403(b) there, as those accounts are considered owned by the employee, so if they own a side business and it has a plan, aggregation for 415 comes into play.

So you are saying contributions to the State Gov't plan are incorporated into the 402(g) calculation?

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TPApril, is the government plan to which the individual is deferring a grandfathered 401(k), a 403(b) or 457(b)? Grandfathered 401(k) or a 403(b) would aggregate, but 457(b) not.

Luke Bailey

Senior Counsel

Clark Hill PLC

214-651-4572 (O) | LBailey@clarkhill.com

2600 Dallas Parkway Suite 600

Frisco, TX 75034

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