IRS Final 430 regs

[My 2 cents]

Do people see what I see in the new final regulations concerning the handling of the quarterly contribution requirements?

1. The regulations finally authorize the use of standing elections to apply balances to meet quarterly requirements,at least for plan years beginning on or after 1/1/16 (if not sooner). They can only be based on the prior year's minimum - no breaks if 90% of the current year's minimum is lower.

2. Questions had been raised whether an election to use balances before the first quarterly deadline sufficient to cover all 4 quarterly amounts could take into account interest, piece by piece, on all 4 quarterly amounts until used (that is, it had been suggested that interest on the amount elected only runs from the beginning of the plan year to the date of election). That appears to have been overturned by the new regulations, which clearly indicate that each unused piece of elected balance would accrue, for purposes of satisfying quarterlies, interest to the date the quarterly was due.

3. Even better, the regulations restore the pre-PPA ability to credit interest on unused pieces of cash contributions from the date made to the date applied against a subsequent quarterly, at least for plan years beginning on or after 1/1/16.