combo db/dc deduction limit

[Tom Poje]

db plan has been frozen for a number of years.

the company put 15% of current comp into the DC plan.

what % can be put into the DB plan since no one is accruing any more - one is simply funding the DB

[Andy the Actuary]

Need a lot more facts, such as what tax year, subject to PBGC, overlapping compensation, non-overlapping compensation, unfunded current liability or funding short-fall, etc. In other words, the scope of your question is broad.

If you're looking for a quick, safe but likely not the optimum answer: 10% of the compensation of the employees covered by the frozen plan, not to exceed the DB plan unfunded whatever using the market value of DB plan assets to value the DB plan unfunded whatever.

Now, the real answer: You should consult with the enrolled actuary who signed the Schedule B.

[Guest Sieve]

I didn't think accuring was the issue. Can't you deduct whatever is necessary to fund as per 412 or 25% of comp for a combintion of plans, whatever is greater? So, if the DB funding + 15% exceeds 25% of comp, you could deduct DC contributions even above the combined 25% to the extent the DC contributions did not exceed 6%. So, if DB funding was 19%-25% of comp, you could contribute & deduct 6% in the DC--the only way you could deduct the entire 15% in the DC would be if the DB was =<10% of comp.

[John Feldt ERPA CPC QPA]

If the DB plan is subject to PBGC and you're looking at a plan year starting on or after 1-1-2008, then there is no limit.

Otherwise, you can ignore the first 6% of pay contribution of employer money to the DC (you can also ignore deferrals). That should get you another 16% of pay contribution to still be within 404(a)(7).