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Schedule A Insurance in a 401(k) Plan


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Guest Frank Jackson
Posted

How should the insurance premiums be reported on schedule A? My service provider is reporting them as allocated. I think they should be unallocated. Is it different for DB vs DC plans? Thanks for the help. Any citations would also help.

Guest Emiliano
Posted

29 CFR 2520.104-44 says that a contract is allocated only if:

- the provider guarantees to provide a retirement benefit of a specified amount

- the specified amount must be fixed without adjustment for fluctuations in the market value of any underlying assets

- and each participant must have a legal right to the amount enforceable directly agains the insurance company (not the plan)

Does this help?

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