Combined plan deductible limit - floor/offset

[tymesup]

404(a)(7) does not apply if no employee is a beneficiary under more than 1 trust. Suppose Joe Cubicle is a participant in a DB plan but has no accrued benefit because it is completely offset by his profit sharing account.

Is he considered a beneficiary under the DB plan?

Thanks in advance for any thoughts on the subject.

[John Feldt ERPA CPC QPA]

Yes.