david rigby

Based on your q16, it appears you are using the GAR94 table, projected to 2002, unisex version. Rev. Ruling 2001-62. a52(12) = 206.300043 a53(12) = 202.771486 (Divide by 12 if needed.) Calculations from a spreadsheet that uses l, v, D, N, etc. Standard "upper 12" approximation. BTW, that table was issued under IRC 417(e). It has since been superseded for 417 purposes.

A sponsor and/or trustee could probably send retirees a W-4P (and state form if applicable) once a year (or once a decade, etc.) if desired, but it should not be required just because the paying organization is changing. Remember: retirees don't like change, so keep it (very) simple.

Why does a retiree need a new W-4P?

Just in case this helps: Gray Book 2010 QUESTION 1 PPA: Funding: Ordering Rules for Contributions In Multiple Employer Plan Plan X, a multiple employer plan to which § 413©(4)(A) applies (thereby requiring the rules of § 430 to be applied separately for each employer under the plan as if each employer maintained a separate plan) has three participating employers A, B and C.. During 2009, B stops contributing to the plan, while A and C make contributions to meet their obligations. As a result, the 2009 Schedule SB will show an unpaid minimum on line 39 attributable entirely to B. a) For 2010, will the ordering rules force any contributions from A or C to go towards meeting the unpaid prior year minimum attributable to B? b) For 2011 and later plan years, will the assets be reallocated so as to bring the assets of the B portion up to the level comparable to that required for a spinoff under §414(l)? RESPONSE a) The rules relating to the ordering rules apply separately to each participating employer so that the UMRC attributable to B will have no effect on the manner in which the contributions from A or C are applied. b) Yes. Under §413©(7), plan assets are reallocated each valuation date in accordance with §414(l) to apply the funding requirement of §413©(4)(A). Prior year receivable contributions are included as plan assets for purposes of this calculation only if they are properly included in assets under §1.430(g)-1(d)(1)(i). The above Response is a summary, prepared by representatives of the Program Committee, of the oral responses to the question posed to certain staff members of the Treasury and IRS, which represent only personal views of the individuals who provided them. Accordingly, the Response does not necessarily represent the positions of the Treasury or the IRS and cannot be relied upon by any taxpayer for any purpose. Copyright © 2010, Enrolled Actuaries Meeting All rights reserved by Enrolled Actuaries Meeting. Permission is granted to print or otherwise reproduce a limited number of copies of the material on the CD-ROM for personal, internal, classroom, or other instructional use, on the condition that the foregoing copyright notice is used so as to give reasonable notice of the copyright of the Enrolled Actuaries Meeting. This consent for free limited copying without prior consent of the Enrolled Actuaries Meeting does not extend to making copies for general distribution, for advertising or promotional purposes, for inclusion in new collective works, or for sale or resale.

Similar prior discussion: http://benefitslink.com/boards/index.php?showtopic=45337

Here are a few prior discussions that you may find useful: http://benefitslink.com/boards/index.php?showtopic=44578 http://benefitslink.com/boards/index.php?showtopic=40213 http://benefitslink.com/boards/index.php?showtopic=38186

Having a bad day, Andy?

Replies in this duplicate post: http://benefitslink.com/boards/index.php?showtopic=46115

Start saving for retirement.

Huzzah! Huzzah!

I heard it at 2008 (09?) EA meeting. The rationale was not explicitly stated, but it was not difficult to read between the lines that he (and/or someone else at the IRS) wanted to keep the 404 upper limit as low as possible. The "rationale" was definitely related to tax revenue.

Not restricted to PPA.

I think you answered your own question. Ned gets them.

There are lots of actuaries more expert at 415 than I, but I don't think it's that simple. For example, if the high-3 comp is $100K (based on some prior years) but the current comp is $50K, the 415 limit will be based on the former. If the current comp and all expected future comp is less than some prior high-3, then the actuary may be able to accomodate your goal. I'll leave it to the experts.

IRS? Really? Not the DOL?

Under PPA, it could be relevant for a DB plan, if the "extra" expense causes the plan's funded ratio to drop below an important trigger.

Not too loud. Congress may think that more taxes is better.

You might have to do your own research, but Carol Calhoun has posted some of hers. http://benefitsattorney.com/index.php

Perhaps, but don't forget the possibilty of indirect costs: smaller asset base may mean larger percentage admin cost for each plan, and/or reduced access to certain investment options or services.

Seems like an expensive audit fee in the example cited. Avoiding an audit fee should be balanced with any increase in other administative costs, both direct and indirect, due to having two plans. I think there are a couple of earlier discussion threads about this.

Consider the possibility that non-payment of premiums is the employee's way of saying, "I'm gone" ?

Look at Act section 201(b)(1), modifying IRC 430©: "... with respect to the shortfall amortization base of a plan for any eligible plan year..." implies that the change is only for the base created in a particular year. Other interpretation may be valid. Is that how you read it?

DOL Reg. 2520.104b-2(a): "... on or before..."

You do not need such a specific reference (although the agent may "need" it). Back up to the first sentence of that first paragraph. "... if any benefits under the plan are provided by an insurance company, insurance service, or other similar organization (such as Blue Cross, Blue Shield, or a health maintenance organization)..." IMHO, you are done proving your point. Ask the agent to prove otherwise.

You could refer to the first paragraph of the Schedule A instructions on page 19: http://www.dol.gov/ebsa/pdf/2009-5500inst.pdf on page