Jump to content

Recommended Posts

Posted

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.

Posted

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.

Posted

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.

Create an account or sign in to comment

You need to be a member in order to leave a comment

Create an account

Sign up for a new account in our community. It's easy!

Register a new account

Sign in

Already have an account? Sign in here.

Sign In Now
×
×
  • Create New...

Important Information

Terms of Use