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Text of IRS CCM 201810008: Application of Sections 401(a)(4) and 401(a)(26) to Cash Balance Plan That Offsets Benefits with Benefits Under a Defined Contribution Plan (PDF)
Internal Revenue Service [IRS] Link to more items from this source
[Official Guidance]
Mar. 9, 2018
"The special rule of Section 1.401(a)(4)-3(f)(9) (under which an employee's accrued benefit under a plan includes that portion of the benefit that is offset by benefits under another plan) applies only to the extent that the benefit is attributable to pre-participation service or past service.... Because, after the offset, NHCEs receive no benefit under the defined benefit plan, the DB/DC plan is not primarily defined benefit in character.... Because the offset must be taken into account and reduces the benefits of NHCEs under the defined benefit plan to zero, the NHCEs do not benefit under the defined benefit plan within the meaning of Section 401(a)(26)(A) and Section 1.401(a)(26)-2(a) and do not have a meaningful benefit under the plan's prior benefit structure as specified in Section 1.401(a)(26)-3(c). Accordingly, the NHCEs are not taken into account for purposes of satisfying the requirements of Section 401(a)(26)."

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