JustMe Posted June 23, 2020 Posted June 23, 2020 I have a DC plan with a 12/31 PYE and a terminating DB combo plan associated with the same employer. I know plans of the same employer with different plan years may be aggregated for ABT testing purposes under 1.410(b)-7(e), but do you just follow the rules of 1.410(b)-5(d)(5)(ii) and add the DC contributions divided by calendar year compensation to DB benefits divided by partial year compensation? Is it that easy or am I missing something? Any different rules when the plan is a short plan year versus just a different plan year?
Mike Preston Posted June 24, 2020 Posted June 24, 2020 8 minutes ago, JustMe said: I have a DC plan with a 12/31 PYE and a terminating DB combo plan associated with the same employer. I know plans of the same employer with different plan years may be aggregated for ABT testing purposes under 1.410(b)-7(e), but do you just follow the rules of 1.410(b)-5(d)(5)(ii) and add the DC contributions divided by calendar year compensation to DB benefits divided by partial year compensation? Is it that easy or am I missing something? Any different rules when the plan is a short plan year versus just a different plan year? It is even easier. Just ignore the plan termination. Continue to aggregate. Be happy.
JustMe Posted June 24, 2020 Author Posted June 24, 2020 By ignore the plan termination, do I use full year compensation for both plans?
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