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IRS Issue Snapshot: Application of Section 415(c) When a 403(b) Plan Is Aggregated with a Section 401(a) Defined Contribution Plan
Internal Revenue Service [IRS] [Guidance Overview] Aug. 18, 2021 "Issue Indicators or Audit Tips: This issue is frequently found during examinations of 403(b) plans maintained by governmental and tax-exempt healthcare entities and colleges/universities.... If outside employment is not permitted, the agent may consider plan aggregation a low audit risk. If the employer is silent about or permits outside employment, determine the procedures used to inform employees about the aggregation rule, and review any notices, forms, or other written communications containing that information. Review any information employees must provide to the employer regarding outside employment and plan contributions." |
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