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Posted

First of all; how low is the stock market going to go? 7000? 6000?

Anyway,

Say a one man plan is implemented where the individual has 5 years of past service at plan inception.

Let's assume we do not have prior years' compensation.

Say in year one he earns 50,000 and in year 2 he earns $0 (but is credited with a year of service). Therefore, the average compensation goes from 50,000 to 25,000.

Say benefit is 10% per year.

Then theoretically in Year 1 his AB would be 5 * .1 * 50k or 25k, limited to 415 limit of say 18,500.

Then after year 2 his AB is 6 * .1 * 25k or 15k.

And a negative accrual results in a negative TNC.

Any problem?

Thanks.

Posted
First of all; how low is the stock market going to go? 7000? 6000?

Anyway,

Say a one man plan is implemented where the individual has 5 years of past service at plan inception.

Let's assume we do not have prior years' compensation.

Say in year one he earns 50,000 and in year 2 he earns $0 (but is credited with a year of service). Therefore, the average compensation goes from 50,000 to 25,000.

Say benefit is 10% per year.

Then theoretically in Year 1 his AB would be 5 * .1 * 50k or 25k, limited to 415 limit of say 18,500.

Then after year 2 his AB is 6 * .1 * 25k or 15k.

And a negative accrual results in a negative TNC.

Any problem?

Thanks.

Maybe not now but someday. If you ask the IRS, based upon their history pre-PPA, they will say, "unh-unh" To quote myself, "the more words the IRS writes, the more they open the possibility for a convoluted or undesirable result." Throughout any past IRS pronunciations regarding reasonable funding methods, negative normal cost was verboten. See IRS Rev. Proc. 2000-40 Section 6.02(6).

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

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