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Has anyone gotten any sense from the IRS lately about whether a cash balance plan with a low, but not variable, interest rate accrual (4%, in my case) can assert that the cash balance account balance is the present value of the accrued benefit? I'm aware that this may not be permitted under the proposed rules of IRS Notice 96-8. However, I'm wondering how the IRS has been reacting to these kind of plans in practice over the last few years.

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