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Guest RBlaine
Posted

Single owner plan. Zero 2008 Schedule C. Large past compensation causes $140k 2008 minimum required contribution.

I know that the MRC can be made without excise tax, but I can't remember what the max contribution can be made without Excise tax.

I think the client is confused because he wants to make the 2008 maximum contribution as calculated by PPA. I'm not sure of the benefit of making a larger than needed non-deductible contribution.

Posted

The excise tax for contributions in excess of the maximum deductible amount was eliminated in 4972 for all db plans that are not multiemployer. If the potential reversion excise taxes don't disuade your client from contributing then perhaps the confusion that exists over whether the amount contributed would ever be deductible at all might.

Guest RBlaine
Posted

Thanks, Mike.

Posted
The excise tax for contributions in excess of the maximum deductible amount was eliminated in 4972 for all db plans that are not multiemployer.

Mike,

Can you elaborate? Does it mean that if the maximum deductible contribution calculated by an actuary is $100,000, and client contributed $150,000, he can deduct $100,000 and not pay the excise tax on $50,000? Will he be able to carry forward this non-deducted $50,000 and deduct it next year?

Posted

Yes. Confusion (I hope the answer is yes, but no regs under 404, to date.

Posted

Depends on your definition of recently. PPA 2006, I think.

  • 3 weeks later...
Guest osmundo
Posted
The excise tax for contributions in excess of the maximum deductible amount was eliminated in 4972 for all db plans that are not multiemployer. If the potential reversion excise taxes don't disuade your client from contributing then perhaps the confusion that exists over whether the amount contributed would ever be deductible at all might.

IRS has publicly stated that 4972©(7) did not eliminate the excise tax on contributions in excess of the maximum deductible contribution

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