401(a)26 with Floor Offset Plan

I am looking at a proposal for a cash balance plan that is offset by employer contributions to a 401(k) plan. It looks like there are 20 eligible employees but only the two shareholders have net contribution credits of more than $280K in the cash balance plan. They are both in their late 50s and the plan has a NRA of 65.

I seem to recall that for purposes of 401(a)26, only the benefits after offset can be considered if they are meaningful (.5% of pay or greater) when a cash balance plan is part of a floor offset arrangement. Whereas benefits before offset are allowed when a traditional defined benefit plan is part of a floor offset arrangement (provided the DC plan has uniform allocations, QJSA etc.) and benefits before offset are meaningful.

Anyone agree / disagree?

I think there is no difference when applying the rules to traditional DB or CB formula. There was some guidance a few years back that clarified  the offset is applied to CB accrued benefit and not current DC contributions versus current CB service credits.

I agree with CuseFan that rules are the same for traditional DB or CB plan. Whether you can offset employees benefits to $0 or not depends on whether offset applied to everyone (owners included) or not. https://www.irs.gov/pub/irs-wd/201810008.pdf