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Section 409(o) payout limits

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I have a calendar year ESOP that normally pays over 5 years of installments except for participants with large balances that may be stretched to up to 10 installment payments.

For a participant with a large balance, if the first installment is paid in 2022 based on the 12/31/2021 share valuation; do you use the 2021 or 2022 409(o) limit to calculate how many years in excess of 5 are used?

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Per the EOB, "The indexed amount applies to any plan year beginning in that calendar year."  I would say that you use the 2022 limits for determining distribution amounts to be paid in 2022. 


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