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Guest Sieve
Posted

Participant A borrows $40,000 from a MPPP (when A's account balalnce is $150,000). Participant A then borrows $30,000 from the same employer's PSP (when A's account balance is $250,000).

The MPPP is then merged into the PSP, and the MPPP trustees assign A's $40,000 note to the trustees of the PSP (who accept the assignment). Does the combined $70,000 worth of loans now in the PSP violate the $50,000 loan limitation of IRC Section 72(p)(2)(A)?

Guest Sieve
Posted

No wonder I've never had this question arise before! You're right: IRC Section 72(p)(2)(D)(ii).

THANKS!

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