415 Limitations

[Gary]

For distributions in 2008 and beyond, I have not seen anything that indicates that the interest rate can be less than the pre PPA rate of 5.5% for 415 limit purposes.

I haven't found a new applicable mortality table after GAR 94. I need to see if the updated mortality table is provided in the PPA funding regs.

Please let me know of any deficiencies in my above comments.

Thank you.

[Blinky the 3-eyed Fish]

The same 5.5% applies.

The change to the new mortality table from 94 GAR has not yet happened but my understanding it's part of technical corrections.

[Gary]

I found the mortality table from Rev Rul 2007-67.

Isn't that the applicable mortality table for 2008 w/r/t minimum funding and minimum lump sums and 415 maximum lump sums?

Thanks.

[Blinky the 3-eyed Fish]

Not the latter as of right now (I mentioned it's part of technical corrections). I don't have time to go through the references though to demonstrate it.

[Guest Deflector]

I also was under the same impression as blinky

[Mike Preston]

I wish somebody would, though, because I was under the impression that the new mortality table WAS in effect for 417(e) and 415 and did NOT require technical corrections. I thought this came from the 415 regulations. That is, we can rely on the regulations, for plan years that begin after the effective date of the new 415 regulations and that regulation references the 417(e) table in effect at the time of distribution. It doesn't specifically say the 417(e) table in effect as of the end of 2007 because that would mean the regs would require updating/amending to reflect any table other than, essentially, 94GAR.

I know that Jim H. said as much at the EA meeting, but, again, I thought this issue was thoroughly vetted back when the 415 regs were finalized and the conclusion at that time was that the 415 regs authorized the use of the 417(e) table.

Maybe WDIK might even have that discussion archived somewhere.

[JAY21]

Hmmm.....I was thinking the same as Blinky so it would be nice to figure out where we stand.