Doctor N is getting a Hypothetical Employer Contribution from cash balance Plan S. Does he get credit for a year of participation for 415(b) purposes?

If not, is there some minimum that would start the clock?

Thanks for any help.

I'm not sure that the receipt of the hypothetical allocation is the trigger for determining whether or not a year of participation for 415(b) has been credited. Isn't this a required definition of the plan document? Usually it is based on hours of service (1000 in most plans, I think). But, if it is based on receipt of a hypothetical allocation then that would be ok, if the IRS approved the language.

The new 415 regs have attempted to tie benefit accrual to years of participation. So you would get your year of participation by earning a benefit accrual (cash balance allocation for service).

You might still get a year of participation if you don't get an allocation, but generally this is tied to some benefit limit in the plan or other 415 limit issue.