Are contributions to a governmental 457(b) plan conisdered annual additions?

[britoski]

I know that 415 limits don't apply to 457(b) plans (not that they would be relevant, since the 457 limits are lower), but for purposes of calculating the annual addition limit for the same employer's 401(a) plan, do you count contributions to the 457(b) plan? In other words, are these contributions "annual additions" for purposes of 415?

[John Feldt ERPA CPC QPA]

No, they are not considered as counting toward the 415 limit in the 401(a) plan.

[Guest Satterfield]

John, do you have a reference that you could provide? Thanks!

[John Feldt ERPA CPC QPA]

Before 2002, a 457(b) plan deferral limit is generally reduced by contributions made under a 403(b) plan (the prior Regulation is 1.457-2(e)(1). This reduction does not apply after 2001 as the regulations were changed - see IRC 457(b)(2). You might also want to look at 1.415(f)-1 Aggregating plans and 1.415-6(b) Annual additions.

[Guest Satterfield]

Great, thanks John!