415 Limits

[Gary]

An EE is a participant of Co. A DB plan.

EE works for Co. B and Co B. pays for the funding requirement to Co. A DB plan for the EE.

CO. A and Co. B are unrelated w/r/t ASG and CG purposes.

EE used to work for Co. A.

While EE was an EE of CO. A , CO. A funded plan on behalf of EE.

Once EE worked for CO. B (when it was first formed 10 years ago), Co. B funds plan for EE.

Is the 415 limit still 185k (at 65) even though each Co has funded and taken deductions for a part of the pension? Or are they separately calculated 415 limits for each period of service for each employer.

Co. A still sponsors the plan. I am not sure, but I think Co. B is taking deductions for these contributions to Co. A's plan.

Now Co. B is going to implement a cash balance plan and there will be coordination of two benefits for 415 purposes.

In the case of CB plan, 415 limit may be lesser of 1) 415 limit to CB plan alone and 2) 415 limit based on total participation in the other plan while Co. B was funding less the benefit accrued by the EE in the other plan while Co. B was funding.

Another thought is to have the CB benefit = Gross CB benefit less the other plan benefit (funded by Co. B) where 415 limit is gross 415 limit in CB plan less benefit in other plan. Thisof course can result in an AB of $0 for several years until the 415 limit in the new plan exceeds the AB in the other plan.

Thanks.

[Effen]

Just a point of clarification, is this a multiple-employer plan?

[Gary]

My understanding is that it is a multi-employer plan, simply because this other employer is contributing to the plan on behalf of some of their employees.

I don't expect that it would be handled in any other way.

Thanks.