A plan terminates 12/31/06 and the one HCE is at the 415 accrued benefit limit at 12/31/06, but distributions are obviously not made until 2007, does anyone think that the 2007 415 limit would then apply to that persons benefit?
Personally, I do not think so because the plan is terminated and all benefit accruals have ceased, but, I would like to be wrong.