Max tax after PPA

[Gary]

Say a plan sponsor made a non deductible contribution for 2009 of 100k.

When computing max deduction under 404(o) in 2010 are the assets reduced by the 100k? It appears not.

So if the assets are not reduced and the max deduction is 400k then it would appear that the prior year 100k would be applied and then an additional 300k to add up to 400k.

And if they did not make a 100k non deductible contribution for 2009 the 2010 maximum would have been 500k instead of 400k due to a lower asset value, thus a 100k deduction is potentially lost.

Pre PPA you would reduce assets by carryover and thus plan would not lose out on 100k deduction.

Any other interpretations?

And re: the 430(i) alternative limit calculation for a small plan. Does the at-risk calculation reflect only the additional actuarial assumptions or the loading factor too?

thanks