"Internal Revenue Code Section 414(v)(7)(A) sets $145,000 (inflation-adjusted) as the limit on a preceding year's FICA wages for a participant not to be constrained to make age-based-catch-up elective deferrals as Roth contributions.... Assuming all relevant years are calendar years: I estimate that, for 2025 FICA wages to drive how Section 414(v)(7) applies for 2026, the $145,000 will become $150,000. BenefitsLink neighbors, is this likely? Or would a Section 415(d)-method calculation come out differently?"

"2 hypothetical scenarios so making things up: Scenario 1: A QRP receives 105k in excess assets from a DB plan and will allocate in 7 years. It is invested in a 0% interest bearing account. Year 1 must allocate 15k (1/7th of 105k) so end of Year 1 balance is now 90k What are the Year 2 and Year 3 requirements assuming minimum will be allocated? Scenario 2: Same as above with the exception it is invested in an account that will have 10% return Year 1 must allocate 15k but now end of Year 1 balance is 99k What are the Year 2 and Year 3 requirements assuming minimum will be allocated?"

"With the new rules, must plans allow all participants the ability to make Roth deferrals? Or can a plan just have the Roth only for when it's required for catch-up?"

"I'm having a lot of trouble with the 280G rules. I have a Disqualified Person who is 100% vested in separation pay. If the DP leaves for any reason, she gets a big payment. She also gets the same big payment (same $ amount) if she is terminated within 6 months of a change in control. We are going to have a change in control and she is going to be terminated. I don't know if the separation payment should be included in the parachute payment calculation.

• On one hand, she is already vested in the total amount of the payment and would have received the payment upon termination regardless of the CIC.
• On the other hand, she is being terminated in connection with the CIC, so the payment is contingent on an event related to the CIC.

The question is, does the payment go into the parachute payment calculation? Since she was already fully vested in the payment, is there some discount on how much is included in the parachute payment calculation. I know the regulations provide rules for 'vested' amounts that are accelerated due to the CIC, but I don't know if that applies here -- and even if it does apply, we have no idea how much the payment was accelerated, since we have no idea when termination would have occurred if not for the CIC (would she have worked 5 more years? 15?)."