CBDB 415 limit calculation with distributions

[Audrey]

if a participant had took a couple distributions and would like to increase the benefit formula to reach 415 limit in 2024

1) should we project the distribution amounts from the distribution dates to 12/31/2024 or simply use the actual distribution amounts?

2) do you normally calculate the 415 lump sum (excluding the exiting distributions) first then back in the accrued benefit/ cash balance credit to reach max 415 lump sum? or do you convert the exiting distributions into accrued benefit then subtract it from the 415 limit? do you handle this differently between DB and CB plans?

3) are there any guidance or regs that can answer these questions?

 

thanks in advance!

[Bri]

I'm hinting that it's not well laid out but there are reasonable interpretations of what to do...

 

[Effen]

If you have access, check out Session 301 Advanced 415 Limits from the 2013 EA meeting, specifically slides 39-61.  There is a good discussion and several examples that might help.  

It's not a simple answer.  

[Audrey]

16 hours ago, Bri said:

I'm hinting that it's not well laid out but there are reasonable interpretations of what to do...

 

Thank you Bri!!! Will read through today

[Audrey]

14 hours ago, Effen said:

If you have access, check out Session 301 Advanced 415 Limits from the 2013 EA meeting, specifically slides 39-61.  There is a good discussion and several examples that might help.  

It's not a simple answer.  

much appreciated Effen!