415 Limit Coordination

[Guest Johnny]

Is there section 415 limit coordination between two nonprofit entities that each offer 401(a) DC plans? Some employees work for both nonprofit entities.

In other words, do we have two of the full $30,000 section 415 limits?

The entities consist of a section 115 school and a separate section 501©(3) hospital.

Thanks,

Johnny

[Carol V. Calhoun]

Good question! No one quite knows how closely two nonprofit organizations have to be before they are treated as a single employer for section 415 purposes. But Notice 89-23 at least contains some general guidance; you might want to check that out.

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