Contribution Limits for off calendar year

[Pammie57]

For a 401k plan that begins  10/1/2017 and ends 9/30/2018 - are they limited to $54,000 or $55,000 in contributions (exclusive of the catch-up)?  Compensation - 270,000 or 275000?  I always get confused on this. 

Thanks 

[Lou S.]

It is split sort of -

415 is based on the limitation year and the end of year limit is what you look at. So assuming your limitation year is the same as your plan year you would look to the 2018 415(c) limit which is $55,000.

401(a)(17) is based on the limitation in effect at the start of the year so the 2017 limit of $270,000.

[401_noob]

Unlike the annual additions limit, the annual compensation limit for an off-calendar plan year is based on the limit that applies for the calendar year in which the plan year begins.

[Tom Poje]

Limit determinations are found in the regs.

most limits are beginning of the year e.g. 1.401(a)(17)-1(b)(3)(ii) "...for the calendar year in which the plan year begins."

The 415 limit is the only limit that is based on the end of the year, e.g. 1.415-5(a)(2)"...applies with respect to limitation years ending with or within the calendar year.

[CJ Allen]

and, 402(g) / 401(a)(30) deferral limit as well as the 414(v) catch-up limit are calendar year limits regardless of the plan year.