Panda Posted October 4, 2024 Posted October 4, 2024 I need help answering this question on Schedule R line 21a. If the employer has 2 plans- a DC plan and a DB plan. The DB plan was frozen a few years ago. Should the plan answer no or yes? Part VII IRS Compliance Questions 21a Does the plan satisfy the coverage and nondiscrimination tests of Code sections 410(b) and 401(a)(4) by combining this plan with any other plans under the permissive aggregation rules? Yes No Thank you.
Bri Posted October 4, 2024 Posted October 4, 2024 I'd say it depends on whether either plan needed the other to pass its tests. With the DB frozen, that sounds like its return should answer no. And unless the DC testing required prior benefit accruals under the DB plan like on an accrued-to-date test, that plan probably should answer no as well, thinking it's passing for 2023 as a standalone plan.
Panda Posted October 4, 2024 Author Posted October 4, 2024 Thank you, Bri. Does it make a difference if the DB plan has a control group? will the answer still be No?
Bri Posted October 4, 2024 Posted October 4, 2024 Should be, since the key point is whether or not the plan itself doesn't pass without aggregation. If the DB plan were the only plan, and it was frozen, nobody would be benefiting at all and therefore wouldn't need another plan to help it pass.
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