Timing of Recognition of Amendments for Valuation Purposes

[Guest HarveyC]

For a 7/1/2001 valuation (for plan year 7/1/2001 - 6/30/2002), can one:

1. Apply EGTRRA 401(a)(17) limits (ie 200K sal cap for all yrs) for this val? Or does one HAVE to use pre-EGTRRA limits for 7/1/2001 val and wait til 7/1/2002 to apply new limits. These new limits have already been adopted and client would like to start funding for this.

2. If plan formula was to be increased effective 7/1/2002, can this be recognized in 7/1/2001 val (and hence set up base for FSA one year ahead of actual increase) or must one wait til 7/1/2002 val? Cost method is FIL.

[MGB]

No. Amendments effective after the plan year may not be recognized.

[Guest HarveyC]

Thanks, MGB. I'm currently reading Rev Rul 77-2 and it supports what you stated.