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Showing content with the highest reputation on 10/25/2015 in Posts

  1. When ERISA was enacted in 1974 all contributions eligible for tax deferral under 403b had to be 100% vested. It was assumed that only vested contributions could be counted for determining the 415 limits. However, in the 90's the IRS published some guide line, ruling etc which concluded that for 415 purposes non vested 403b contributions would be included as employer contributions in the year the contributions were made instead of in a later year when they were vested which permitted employees to receive the max amount under the 415 limits in each year they participated in the plan. So providers began including language that allowed for deferred vesting of 403b contributions up to the 415 limits. To comply with the non reversion provision of ERISA 403c the plans contain a provision that forfeited amounts are transferred to side fund or suspense account in the contract that is used to fund contributions in the following plan year.
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