415 limit question

[dmdavala]

I have a plan that has a very rich death benefit. If an active participant dies then the spouse gets a 100% J&S payable immediately. There is no reduction for early retirement. The normal form for the plan is 10cc. The benefit is converted to 100% J&S using the plans factors.

A participant aged 45 died. The spouse is 41.

My question is how to calculate the 415 limit on the benefit.

I assume that I would reduce the dollar and pay limits to age 45 by using plan and applicable assumptions and take the lesser of these.

What if the spouse decides not to immediately commence benefits? The plan provides for actuarial increase from the date the benefit could have commenced. (Month following death)

The benefit will increase each month. Does the 415 limit increase each month also?

Do I use the participant's age or the surviving spouse's when calculating the limit?

[tymesup]

The death benefit is not subject to the 415 limit.

It is limited to being an incidental benefit.

[david rigby]

The plan might define the death benefit in a way that includes the 415 limit.

[tymesup]

To correct my old post, insurance is not directly subject to the 415 limit. If the death benefit was equal to the PVAB, then 415 would limit the accrued benefit and the PVAB.

My bad.