LIBOR
Jun 22 2004, 09:21 AM
I have a client who would like to freeze their DB plan; but prior to the freeze they want to amend the plan to provide 3 additional years of service for any participants with combined age plus service in excess of 80.
Are there any potential non-discrimination issues here ?
Can anyone think of any problems of any nature with this prposal ??
pax
Jun 22 2004, 10:01 AM
Potential? Sure.
How about "benefit, rights, and features"?
Effen
Jun 22 2004, 10:05 AM
Well, obviously the amendment can't discriminate in favor of HCEs. Would they need to check back-loading issues?
Also, it won't help reduce the excise tax if that is what they are after. I believe it would have to be a pro-rata increase to reduce the excise tax.
LIBOR
Jun 22 2004, 10:08 AM
BRF's - yes !! and that in and of itself is enough of an issue !! thanks Pax !!!
LIBOR
Jun 22 2004, 10:11 AM
Effen , could you elaborate more on the excise tax issue - I'm not sure I know what you mean ?
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