415 limit

[dmb]

I seem to be receiving conflicting answers. Do deferrals to a 403(b) plan (other than an educational organization or hospital) count against the 415 limit for DC plans?? Thanks.

[Guest mike webb]

Yes, but such deferrals would NOT be aggregated with a seperate qualfied (401(a)) plan of the same employer for 415 limit purposes. See Treas Reg. 1.403(b)-4(b)(2).

[Guest mjb]

I seem to be receiving conflicting answers. Do deferrals to a 403(b) plan (other than an educational organization or hospital) count against the 415 limit for DC plans?? Thanks.

The rules for aggregating 403b plan contributions with an employer sponserd plan are in Reg 1.415(f)-1(f). For example aggregation under 415 is required if an employee who participates in a 403b plan also is the sole owner of a business that maintains a SEP or HR-10 plan.

[Guest B2Randolph]

One very good thing about 403(b) plans in conjunction with qualified plans is that both 403(b) and 401(a) plans have separate 415 limits - in other words, you could effectively contribute 46,000 in each plan. So, you can have a 403(b) with deferral and match - assuming $15,500 contributed and a 200% match, you would total $46,500, so you would have to limit to 200% match so it doesn't exceed 415.

Then establish a PSP or MP plan which receives a $46,000 contribution.

All this is perfectly legitimate.

AND you could also establish a 457(b) top hat plan to accept another $15,500.

Pretty sweet, huh!