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Interpretation of Code Section 415(b) Related to Reduced Early Retirement Benefits and Qualified Joint and Survivor Annuities (PDF)
Gabriel, Roeder, Smith & Company 
[Guidance Overview] Sept. 30, 2013
"According to the 2013 Gray Book [of the American Academy of Actuaries]... the early retirement reduction factor and the optional form factor apply to the accrued benefit (rather than the formula benefit), which must be limited to the Section 415(b) limit applicable at the plan's normal retirement age.... [This] interpretation ... could significantly and unexpectedly limit the benefits that plans can pay to some participants. Although the Gray Book is not authoritative, it does reflect the views of certain U.S. Treasury and IRS staff."
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