415 annual additions limit

[Santo Gold]

An owner of a small business has as employees, himself, his wife and an assistant. He also has about a dozen CBA employees.

The owner is also a union member.

The owner pays into the unions multi-employer plans for the union members, which includes himself. This includes both a union DB and DC Plan.

In the meantime, the owner establishes a 401(k) Plan for himself, wife and assistant, but excludes non-owner CBA employees.

Question #1: Can he achieve $49,000 (under age 50) in the company's plan? Or does the $49,000 limit include the contributions from both the company plan and the union DC plan.

Question #2: Does the union DB plan affect his $49,000 limit?

Thanks

[Guest Sieve]

1) The annual addition limitation includes all DC plans in which an employee participates as an employee of any single employer, whether union or non-union. So, allocations to the union DC plan will reduce the permissible allocations to the non-union DC plan.

2) The DB plan accruals will not impact the DC annual addition limitations.