There's a cash balance plan with the annual benefit going to the owners (HCE's) in the plan that is above their 415 limits. If their benefit is limited, the thought is to have the plan buy each of them an annuity with a X% surrender charge. This would make the taxable distribution effectively identical to the 415 limit. The annuity would be transferred to them for conversion to an IRA after IRS approval was received. We would offer this identical distribution to the other participants.
Any thoughts on this?