415 LS

[thearchitect]

On Page 64 of Dave's 2012 ASM manual for EA-2B it states the 415 LS factor is the lesser of: 1. AE plan assumptions or 2. 105% 417e if applicable or 3. AMT and 5.5%.

However, code section 415(b)(2)(E)(v) and 415(b)(2)(E)(ii) state that 415 LS factor is based on the lesser interest rate of: 1. AE plan assumptions or 2. 105% 417e if applicable or 3. AMT and 5.5%. It states the mortality table to use should be AMT regardless of the lowest interest rate. Did WRERA or some other law change this section?

The example on pages 90-92 agrees with the description on page 64.

Thanks.

[lttownsend]

Originally Posted by thearchitect

On Page 64 of Dave's 2012 ASM manual for EA-2B it states the 415 LS factor is the lesser of: 1. AE plan assumptions or 2. 105% 417e if applicable or 3. AMT and 5.5%.

However, code section 415(b)(2)(E)(v) and 415(b)(2)(E)(ii) state that 415 LS factor is based on the lesser interest rate of: 1. AE plan assumptions or 2. 105% 417e if applicable or 3. AMT and 5.5%. It states the mortality table to use should be AMT regardless of the lowest interest rate. Did WRERA or some other law change this section?

The example on pages 90-92 agrees with the description on page 64.

Thanks.

Check out the 415 regulations. They are quite a bit different than the IRC and explain the more complicated methodology of using plan assumptions and statutory assumptions to calculate the 415 maximum annuity payment at distribution age and corresponding maximum lump sum.