Ted Munice Posted January 24, 2019 Posted January 24, 2019 Did the IRS issue some sort of guidance or notice in 2017 effective for 2018 that restricted what assumptions could be used in a beginning of year valuation? Specifically did they state that for a participant you must assume 2018 expected compensation and expected hours must be the actual 2017 compensation and hours?
Effen Posted January 24, 2019 Posted January 24, 2019 No, there was no new guidance issued that I am aware of. 2018 expected compensation should be a reasonable expectation. Generally, that would be 2017 w/ a salary scale adjustment, or pro-rata adjustment if they worked less than a year. What is the basis of your question? What would you like to use? The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.
digger Posted January 24, 2019 Posted January 24, 2019 I, too, always thought of compensation as an assumption. But then IRS issued Rev Proc 2017-57 describing the procedure to request approval of a change in funding method. In that RP, IRS describes a change in certain "data elements" as a method change requiring approval. This is one of their examples of a change in method requiring approval: Example 5 – The plan year is the calendar year and the valuation date is January 1. For the prior plan year, the data element used to project future compensation was the actual annual compensation (as reported on Form W-2, "Wage and Tax Statement"), for the plan year preceding the valuation date. For the current plan year, the data element used to project future compensation is the monthly rate of pay as of the valuation date.
C. B. Zeller Posted January 25, 2019 Posted January 25, 2019 The definition of target normal cost in 430 specifically says that you can include increases in compensation for the current year. However if you are changing the data elements used to determine the current year comp, then that would be a change in method that requires approval as @digger said. ugueth 1 Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance. Corey B. Zeller, MSEA, CPC, QPA, QKA Preferred Pension Planning Corp.corey@pppc.co
david rigby Posted January 25, 2019 Posted January 25, 2019 The original Q was about assumptions. If you need to change your salary increase assumption, do it. Keep a record of why and what data is used for your conclusion. IMHO, you should also include reasonable (not necessarily detailed) discussion in your actuarial report. Don't forget the 5500 attachment. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
digger Posted January 25, 2019 Posted January 25, 2019 If my 2018 report disclosure of method and assumptions says expected compensation is last year's comp (with or without a scale) and the business owner reports he is paying himself less this year based on business projections, can I suddenly assume the scale is negative 50%?
david rigby Posted January 26, 2019 Posted January 26, 2019 Several times, I've changed my salary assumption. (Example1, 2009 recession. Example2, immediately following a very good year in which sales commissions were unusually large and not expected to recur.) It may also be valid to have different assumptions for different groups/locations/etc. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
Ted Munice Posted February 5, 2019 Author Posted February 5, 2019 Normally we would assume that for a 1/1/2018 valuation, for instance, we would assume 2018 compensation and hours of service will be the same as 2017. We may or may not have a salary scale assumption. But what if we WANT to assume that 2018 compensation and hours are significantly less that the 2017 experience - such that we are in essence assuming no accrual for 2018 even though the participant had an accrual in 2017. Rev Proc 2017-57 seems to indicate that is a change that requires IRS approval for a BOY valuation. Am I interpreting that correctly?
C. B. Zeller Posted February 5, 2019 Posted February 5, 2019 2017-57 is about changes in method. You have a change in assumptions. See, for example, Section 3.02(c) Example 3 of the rev proc. Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance. Corey B. Zeller, MSEA, CPC, QPA, QKA Preferred Pension Planning Corp.corey@pppc.co
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