415 limits for 403(b) Plans

[Guest PGH.ERISA]

Section 1.415©-2(g) of the final 415 regs follows the Code and provides that compensation used in performing 415 testing on 403(b) plans is "the participant's includible compensation determined under

 section 403(b)(3).  Accordingly, the rules for determining a participant's compensation pursuant to section 415©(3) (other than section 415©(3)(E)) and this section do not apply to a section 403(b) annuity contract."  In reading that, I figured that the $200,000 (as adjusted) compensation limit set forth in 1.415©-2(f) would not be applicable to a 403(b) plan, but I see that the IRS model 403(b) plan in Rev. Proc. 2007-71 states that includible compensation used for 415 testing is subject to the 401(a)(17) cap.  What gives?  Where is the authority for this, given the language in the regulations?

[Guest KTP]

See Treas. Reg. § 1.403(b)-5(a)(1)(ii).

[Guest Sieve]

And, perhaps more importantly, IRC Section 403(b)(12)(A)(i) (but, not applicable to church 403(b) annuity contracts pursuant to IRC Section 403(b)(1)(D) & Treas. Reg. Section 1.403(b)-5(d)).