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Do we now need two assumptions? One for computing TNC under 430 and the other for computing the cushion amount for maximum deduction purposes under 404(3)(A). It would seem like the first would be established each year to reflect expected practice while the second would be reviewed for appropriateness from time to time but likely would remain constant (unless it were tied to the change in discount rate).

Any thoughts?

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

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