415 and off calendar year plan year

[30Rock]

I just want to confirm what the 415 limit will be for a plan year than runs from 7/1/23-6/30/24? It seems to me that it is based on the limit for 2024 but I do not have that yet. Thank you!

[Lou S.]

415 is limit is based on PYE, so in your case, yes, 2024. And you won't know that until sometime in October.

402(g) limit is always calendar for the participant.

401(a)(17) is based on PYB, so that would be 2023 in your example.

[Belgarath]

To be very nitpicky, the 415 limit is based on the calendar year limit in which the limitation year ends, right?

[Peter Gulia]

And might a limitation year be specified differently than a plan year?

Perhaps another RTFD moment?

[Lou S.]

Yes the limitation year can be different in the document and there are rules in the code about the limitation year as well as any changes if you want to change the limitation year or you have a short limitation year. The most common limitation years are either the "Plan Year" or the "calendar ending within the Plan Year" but I believe the limitation year can be any 12 consecutive month period though I think it has to have some over lap with the plan year.

[CuseFan]

You're talking DC plans, because DB 415 limit is based on calendar year in which the limitation years begins, correct?

[Tom]

And the permitted disparity level for a plain vanilla integrated with social security profit sharing is the amount for the calendar year that contains the first day of the plan year I believe. So for a year ending 9/30/2023 it is $147,000 (assuming based on 100%).