Mel_1999 Posted April 26, 2017 Posted April 26, 2017 We have a profit sharing plan (12/31 PYE) that currently has an integrated ps formula with an accrual requirement of 1,000 hours and last day. The client wants to amend the profit sharing formula to cross-tested and remove all accrual requirements effective January 1, 2017. If we are removing the accrual requirements for receiving profit sharing contributions, can it still be amended for the 2017 PY to change the contribution formula?
KJohnson Posted April 26, 2017 Posted April 26, 2017 Does it waive the accrual requirement for death, disability and retirement? And, if it does is there anyone that has had one of those events?
Mel_1999 Posted April 26, 2017 Author Posted April 26, 2017 56 minutes ago, KJohnson said: Does it waive the accrual requirement for death, disability and retirement? And, if it does is there anyone that has had one of those events? No it does not.
KJohnson Posted April 26, 2017 Posted April 26, 2017 Might want to look at TAM 9735001 https://benefitslink.com/src/irs/tam9735001.html Slides 4 and 5 of this relatively recent ASPAA program are good https://www.asppa.org/Portals/2/PDFs/2016AnnualHandouts/WS63 - The Anti-Cutback Rules of IRC 411d6.pdf Seems to me that nobody has accrued any benefit for the year under the old formula and you should be able to amend even if the new formula has no allocation conditions.
Mel_1999 Posted April 27, 2017 Author Posted April 27, 2017 15 hours ago, KJohnson said: Might want to look at TAM 9735001 https://benefitslink.com/src/irs/tam9735001.html Slides 4 and 5 of this relatively recent ASPAA program are good https://www.asppa.org/Portals/2/PDFs/2016AnnualHandouts/WS63 - The Anti-Cutback Rules of IRC 411d6.pdf Seems to me that nobody has accrued any benefit for the year under the old formula and you should be able to amend even if the new formula has no allocation conditions. Thanks so much for your help on this.
Recommended Posts
Create an account or sign in to comment
You need to be a member in order to leave a comment
Create an account
Sign up for a new account in our community. It's easy!
Register a new accountSign in
Already have an account? Sign in here.
Sign In Now