LIBOR Posted June 22, 2004 Posted June 22, 2004 I have a client who would like to freeze their DB plan; but prior to the freeze they want to amend the plan to provide 3 additional years of service for any participants with combined age plus service in excess of 80. Are there any potential non-discrimination issues here ? Can anyone think of any problems of any nature with this prposal ??
david rigby Posted June 22, 2004 Posted June 22, 2004 Potential? Sure. How about "benefit, rights, and features"? I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
Effen Posted June 22, 2004 Posted June 22, 2004 Well, obviously the amendment can't discriminate in favor of HCEs. Would they need to check back-loading issues? Also, it won't help reduce the excise tax if that is what they are after. I believe it would have to be a pro-rata increase to reduce the excise tax. The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.
LIBOR Posted June 22, 2004 Author Posted June 22, 2004 BRF's - yes !! and that in and of itself is enough of an issue !! thanks Pax !!!
LIBOR Posted June 22, 2004 Author Posted June 22, 2004 Effen , could you elaborate more on the excise tax issue - I'm not sure I know what you mean ?
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