Short limitation period when plan year is changed - am I reading reg c

[John A]

Say a 2000 calendar limitation year is changed to a limitation year of 7/1/00 to 6/30/01. Is the 415 dollar limit prorated for the period 1/1/00-6/30/00 or 1/1/01 to 6/30/01? Before you answer, please read the following excerpt from IRS Reg. 1.415-b(4):

(4) Effect of change of limitation year.

...

(ii) Any change in the limitation year must be a change to a twelve-month period commencing with any day within the current limitation year.

(iii) For purposes of this paragraph, the limitations of section 415 are to be applied in the normal manner to the new limitation year. Moreover, the limitations of section 415 are to be separately applied to a “limitation period” which begins with the first day of the current limitation year and which ends on the day before the first day of the first limitation year for which the change is effective. The dollar limitation with respect to this limitation period is determined by multiplying (A) the applicable dollar limitation for the calendar year in which the limitation period ends by (B) a fraction, the numerator of which is the number of months (including any fractional parts of a month) in the limitation period, and the denominator of which is 12. This adjustment of the dollar limitation only applies to a defined contribution plan.

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It appears to me that "the day before the first day of the first limitation year for which the change is effective" in my answer above is 6/30/00.