401(a)(17) Limit in Year of Plan Freeze

mardi 3 février 2015

I have a client that froze their QP on 3/31. There is an exec who is generally over the 401(a)(17) comp limits annual. How is his 1/1 - 3/31 pay treated in the year of the freeze?



I would think the limit is not prorated, as the plan does not have a short plan year. I think this falls into IRC § 1.401(a)(17)-1(b)(3)(iii)(B), but wouldn't mind another opinion.



Thanks!





401(a)(17) Limit in Year of Plan Freeze

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