Pension Protection Act Blog

The IRS released a short two-page summary of the Final 415 Regs in the form of a special edition of Employee Plan News. The summary for the items changed by the Pension Protection Act are:

The following modifications to section 415 made by the Pension Protection Act of 2006:

i. changes to the interest rate assumptions in section 415(b)(2)(E) that are used for converting certain forms of benefits to an equivalent straight life annuity;

ii. elimination of the active participation requirement in determining a participant’s high-3 years of service in section 415(b)(3);

iii. exemption from the section 415(b)(1)(B) compensation limit for certain benefits provided under a defined benefit plan maintained by an organization described in section 3121(w)(3)(A); and

iv. expansion of the definition of qualified participant in section 415(b)(2)(H) to include certain participants in a defined benefit plan maintained by an Indian tribal government.

According to the summary, some other important changes made by the Final 415 Regs are several changes to the definition of 415 compensation and “repeal of the section 415(e) combined limitation on participation in a defined benefit plan and a defined contribution plan”.

Another note is that Monika Templeman has been promoted to the Director of EP Examinations effective April 1, 2007.

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