DB/DC deduction limit after PPA 2006

[YankeeFan]

Lets assume an employer sponsors both a defined benefit plan and a defined contribution plan.

Is it everyone's understanding that in the DB plan the client can contribute (and deduct) the greater of:

1) Up to 100% of current liability; or

2) Up to 25% of eligible compensation; or

3) The amount necessary to meet minimum funding (even if it exceeds (1) and (2))

PLUS

Up to 6% of eligible compensation in the DC plan (not including 401(k) deferrals)?

If you read IRS Notice 2007-28 (Question 9), the answer states that the DB plan deduction is limited to the greater of (1) or (2) above.

For example, lets assume the following:

a) eligible compensation is 50,000

b) required minimum contribution is 100,000

c) Current liability is 1,000,000

d) Plan assets are 960,000

e) up to 6% of eligible compensation has been contributed to the DC plan

Can you contribute and deduct 100,000 to the DB plan or is the DB deduction limited to 40,000 (CL of 1,000,000 less assets of 960,000)?

[Guest Carol the Writer]

My understanding was that the deduction was, in any case where there was a DB and DC plan, liited to the sum of

1. The amount requred to meet minimum funding (in your example, $100,000)

PLUS

$ An amount not to exceed 6% of compensation, if that amount is contributed to the DC plan.

[Guest MMorgan]

If this plan had a 401k feature, you would also be able to include deferrals, right?

[John Feldt ERPA CPC QPA]

Yes.