Jump to content

415(c) Limit Question


Guest wwc870
 Share

Recommended Posts

The participant is treated as the sponsor (for 415 purposes) of his/her own 403(B) contract, regardless of whether the 403(B) plan is an ERISA plan. If the participant is only an employee of his/her employer, there will be a separate 415 limit for the 401(a) plan. The 415 limit on the 403(B) limit will be aggregated with any other 403(B) arrangements in which the participant contributed this year.

Link to comment
Share on other sites

  • 4 months later...
Guest mike webb

Does new Code Section 415(k)(4) (below) as added by EGTRRA, affirm the separate 415 limits for 401(a) and 403(B) plans when the person does not own or control more than 50% of the 401(a) sponsoring employer and Special Election 'C' (no longer applicable in 2002 and beyond) is not used? It seems clear that this section recodifies the separate limits, but I've seen at least one publication from a major consulting firm that states the opposite conclusion.

(4) Special Rules For Sections 403(B) And 408.--

For purposes of this section, any annuity contract described in section 403(B) for the benefit of a participant shall be treated as a defined contribution plan maintained by each employer with respect to which the participant has the control required under subsection (B) or © of section 414 (as modified by subsection (h)). For purposes of this section, any contribution by an employer to a simplified employee pension plan for an individual for a taxable year shall be treated as an employer contribution to a defined contribution plan for such individual for such year.

Link to comment
Share on other sites

The consensus is that we still have the two separate 415© limits, and the section you quoted, Mike, is a technical correction to the prior repeal of 415(e).

Keep in mind that you must aggregate the 415© limits in situations where a 403(B) participant has an outside business which he or she controls, and has a qualified plan or a SEP.

Finally, Option C will not be an issue after January 1, 2002, since as indicated, it is repealed.

Link to comment
Share on other sites

I was wondering about this myself. I didn't look at the conference committee report on this, because I deal very little with 403(B)'s. Was this intentional, or is this a likely target for a technical corrections bill, since EGTRRA axed the exclusion allowance calculation, thereby making the 403(B) tantamount to the "old" C election? Obviously you use the law as is until changed, but for those of you more in tune with the 403(B) world, would appreciate your thoughts on this.

Link to comment
Share on other sites

If you mean "was the intention to allow two separate 415© limits - one for 401(a)/401(k), and another for 403(B)" - I am assured it was intentional.

Keep in mind that the ownership and control issue (e.g., participant owns/is in control of the 403(B) plan)has been the case with 403(B) plans for as long as I can remember (and that is a long time), and, with the exception of catch up option C, has always resulted in two separate limits when the plans are sponsored by the same employer. The technical corrections in EGTRRA was because the language needed to be re-added after the repeal of 415(e) unintentionally took it away. The only real change for next year in that particular issue is that option C goes away - thus, there will be two limits (except in the case of ownership of an outside business as I said.

On the other hand, I never say never. Have already heard an unsubstantiated rumor that 403(B) "non-aggregation" may be the topic of new legislation at some point - after all, it flies in the face of benefiting rank and file employees and is usually constructed to benefit the honchos. We'll see. Pretty strong lobbies want to keep it the way it is.

Link to comment
Share on other sites

Create an account or sign in to comment

You need to be a member in order to leave a comment

Create an account

Sign up for a new account in our community. It's easy!

Register a new account

Sign in

Already have an account? Sign in here.

Sign In Now
 Share

×
×
  • Create New...