luissaha Posted June 8, 2022 Posted June 8, 2022 A governmental employer sponsors a 401(a) defined contribution plan, a 401(K) plan, and a 457 (b) plan. For purposes of the annual contribution limits under 415 (c), are the 457 (b) plan contributions treated separately, or are they combined with the 401(k) and 401(a) contributions?
Carol V. Calhoun Posted June 8, 2022 Posted June 8, 2022 They are treated separately for purposes of the 415(c) limits. Of course, deferrals under 401(k) and 403(b) plans of separate employers are aggregated for purposes of the 402(g) limits. 457(b) plans are subject to separate limits, regardless of whether it is one employer or more than one. (And of course, a state or local government can't have a 401(k) at all unless it is a grandfathered 401(k).) Luke Bailey 1 Employee benefits legal resource site The opinions of my postings are my own and do not necessarily represent my law firm's position, strategies, or opinions. The contents of my postings are offered for informational purposes only and should not be construed as legal advice. A visit to this board or an exchange of information through this board does not create an attorney-client relationship. You should consult directly with an attorney for individual advice regarding your particular situation. I am not your lawyer under any circumstances.
luissaha Posted June 8, 2022 Author Posted June 8, 2022 Regarding deferrals, does that mean combined deferrals to the 401(k) and 457 (b) plans cannot exceed $20,500 for 2022? I thought an employee could defer $20,500 to each plan for a total of $41,000. The 401(k) is grandfathered, so this is a bit of an odd case. Strange the employer has a 401(k) and 457 plan.
Luke Bailey Posted June 9, 2022 Posted June 9, 2022 22 hours ago, luissaha said: Regarding deferrals, does that mean combined deferrals to the 401(k) and 457 (b) plans cannot exceed $20,500 for 2022? I thought an employee could defer $20,500 to each plan for a total of $41,000. The 401(k) is grandfathered, so this is a bit of an odd case. Strange the employer has a 401(k) and 457 plan. Not combined for deferrals under 402(g). They can double up. Luke Bailey Senior Counsel Clark Hill PLC 214-651-4572 (O) | LBailey@clarkhill.com 2600 Dallas Parkway Suite 600 Frisco, TX 75034
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