Combo Plans Non Discrimination

[Gary]

In designing a combo plan let's say we test the plans using the general test on a combined basis for non discrimination.

I will be doing my own research on these matters as well, but this is a good jump start.

1. Say the new DB plan wants to provide up to 5 years past service and the 401k profit sharing plan is a new plan as well. Any cite that precludes combined plans being tested on an accrued to date basis? Of course the accrued pension benefit may be based on 5 years of past service for a given individual and the accrued to date method would cause accrued benefit to be divided by 5, while the profit sharing contribution is a total based on the one year.

2. Any cite that precludes an offset of employer provided defined contribution benefit for some employees?

3. And let's say instead that the DB plan is a cash balance plan where the AB is the account balance. Does this mean that the allocation method is based on the account and the accrual method must convert to an annuity benefit? Essentially the accrual method in the cash balance plan would end up being the cross testing.

If the cash balance accrued benefit were stated as an annuity than I would say the annuity would need to be converted to an allocation to test on an allocation basis, but being post PPA presumably the account balance can in fact be the accrued benefit payable.

In conclusion, I'm really looking for specific citations to refer to, when known.

Thanks.