Vlad401k Posted October 16, 2017 Posted October 16, 2017 Let's say that there is plan that defines a plan year as 1/1 to 12/31. The limitation year is based on the plan year, so if the plan is terminated, the 415 and 401(a)17 limits will be pro-rated. What if the plan terminates of 3/2/2017? How would the limits apply? Specifically, since the plan terminated during the month of March, should be limits be: 1) 270,000 * (3/12) and 54,000 * (3/12) for 401(a)17 and 415, respectively. or, 2) 270,000 * (61/365) and 54,000 * (61/365) for 401(a)17 and 415, respectively. Basically, when the pro-rated computation is done, is it based on the number of months or the number of days? Thanks in advance.
Tom Poje Posted October 16, 2017 Posted October 16, 2017 A reading from the book of Regulations Section 1.415(j)-1(d)(2) .....multiplying the applicable dollar limitation for the calendar year in which the limitation period ends by a fraction, the numerator of which is the number of months (including any fractional parts of a month)... to make it fun 1.401(a)(17)-1(b)(3)(iii) simply says the numerator of which is the number of months in the short plan year, the denominator is 12 (no mention of using fractional periods) of course every example I have ever seen always had a plan year ending at the end of the month. YogaTPA, ESOP1 and Bill Presson 3
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