415 Limit on 1st Day of Plan Year

[JAY21]

I believe we've discussed that a new plan effective say 1/1/08 can be treated for funding purposes as if 1/10th of the 415 limit was available (allowed) on the first day of the plan year (1/1/08).

Is this a special rule just for the first plan year only ? or for the second year (2009) for funding purposes could you treat it as if you had 2/10ths of the dollar limit on 1/1/2009 ?

[ak2ary]

The 415 dollar limit phases in over the first 10 years of participation but is never less than 1/10th of the full dollar limit. But it is no help in year 2

[david rigby]

Correct.

See IRC 415(b)(5), and don't forget to read subparagraph ©:

http://www.fourmilab.ch/ustax/www/t26-A-1-D-I-B-415.html

[Andy the Actuary]

Won't this work if the plan credits a year of participation for performance of one-hour of service and the participant gets up early?

[Mike Preston]

Don't think so.

[JAY21]

Since the special 415 rule is no help in 2nd year (2009) then I guess the strategy of using past service credit for a new 2008 plan in order to create/fund full target liability cushion of 50% is a help in 1st year of plan (2008), but second year of plan since your past service liability at 1/1/09 is still just 1/10th of 415 YOP you have created a shortfall gain in year 2 for minimum funding (since you already funded 150% of target liability in 1st year) which partially offsets your normal cost for minimum funding in 2009, so your maximum 2009 is probably just roughly equal to normal cost since 150% of target liability (1/10th of dollar limit) has not changed since prior year and was already funded in 1st year

Ignoring at-risk assumptions impact on max contribution for the moment, does this sound right ? Corrections ?