JAY21 Posted September 15, 2006 Posted September 15, 2006 If a DB & DC plan are permissively aggregated then under the (a)(4) regs does the vesting schedule have to expressly be the same under both plans, or just tested as non-discriminatory on the current avail/effective avail test ? I don't see in the (a)(4) regs where it states that they have to be the same. I would assume though that having only NHCEs in the DC plan and it having a lesser vesting schedule than the DB plan, though still a statutory schedule, would be discriminatory ? any thoughts ?
Blinky the 3-eyed Fish Posted September 15, 2006 Posted September 15, 2006 They don't need to be the same, just tested as a BRF. Sounds like your arrangement has issues. You could always go for a ruling from the IRS (Demo 3 I believe). "What's in the big salad?" "Big lettuce, big carrots, tomatoes like volleyballs."
Recommended Posts
Create an account or sign in to comment
You need to be a member in order to leave a comment
Create an account
Sign up for a new account in our community. It's easy!
Register a new accountSign in
Already have an account? Sign in here.
Sign In Now