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Bottom Up QNEC


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Posted

I remember reading something recently regarding the IRS not being too happy about using the bottom up QNEC but I can't put my hands on it. Anyone know where I can find this info?

Posted

I think it was in connection to the fact that EGTRRA changed the limit on DC annual additions to 100% of pay. In a bottom up QNEC situation, you end up giving 4 times as much as you would have under the old rules where the limit was 25% of pay to the lowest paid individual. The guidance we will get will be with respect to implementation of EGTRRA. Look for it sometime in 2006 or 2007. ;-)

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