What limits to pro-rate for short initial years?

[BG5150]

I have a calendar year plan that has an effective date of 3/1/2006. What limits do I pro-rate for the year if any?

[Tom Poje]

How is the definition of limitation year defined in the document?

[BG5150]

How is the definition of limitation year defined in the document?

12 months prior to last day of plan year. (I believe)

[Tom Poje]

well, from my notes from prior conferences:

only mention of pro rating 415 limit is with a change in limitation year. you don't have that. at 1996 asppa conference the response was 'there is no initial short limitation year. it is a full 12 month period working backward from end of the year.

pro ration of comp limit:

depends on the period used for determining allocations. and it is certainly possible to use a 12 month period ending with in the plan year, so that would be a document issue.