Section 415 pet peeve

[Gary]

When adjusting the 415 dollar limit for benefit commencement before age 62 during plan year 2008.

I have read sources that indicate the mortality to make adjustments for payment before age 62 to the dollar limit is done using GAR 94 for benefit commencement in 2008 plan year. That is, the app table before 2008.

Of course there was a new app mort table in 2008 I would expect that table to be used for 415 dollar adjustments.

I also bellieve I have read in a more recent source that it is indeed the new app mort table.

Which one is it? And can you provide a pertinent cite?

Thanks.

[AndyH]

WRERA I believe made the 415 table be the 417(e) table.

[SoCalActuary]

When adjusting the 415 dollar limit for benefit commencement before age 62 during plan year 2008.

I have read sources that indicate the mortality to make adjustments for payment before age 62 to the dollar limit is done using GAR 94 for benefit commencement in 2008 plan year. That is, the app table before 2008.

Of course there was a new app mort table in 2008 I would expect that table to be used for 415 dollar adjustments.

I also bellieve I have read in a more recent source that it is indeed the new app mort table.

Which one is it? And can you provide a pertinent cite?

Thanks.

For any 2008 amounts before enactment of WRERA, you did use the 94 GAR, because the law did not reference 415 for mortality changes. With WRERA, the table is conformed to 417. For 2008, therefore, you still had a gray area, and I recall that you were allowed to keep the 94 GAR for that year.