IRS Announces Pension Plan Limitations for 2005
The Internal Revenue Service recently announced cost of living adjustments
applicable to dollar limitations for pension plans and other items for Tax Year
2005.
Section 415 of the Internal Revenue Code provides for dollar limitations on
benefits and contributions under qualified retirement plans. It also requires
that the Commissioner annually adjust these limits for cost of living increases.
Many of the pension plan limitations will change for 2005. For most of the
limitations, the increase in the cost-of-living index met the statutory
thresholds that trigger their adjustment. Furthermore, several limitations, set
by the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA), are
scheduled to increase at the beginning of 2005.
For example, under EGTRRA, the limitation under section 402(g)(1) on the
exclusion for elective deferrals described in section 402(g)(3) is increased
from $13,000 to $14,000. This limitation affects elective deferrals to section
401(k) plans and to the Federal Government's Thrift Savings Plan, among other
plans.
Cost-of-Living limits for 2005
Effective January 1, 2005, the limitation on the annual benefit under a
defined benefit plan under section 415(b)(1)(A) is increased from $165,000 to
$170,000. For participants who separated from service before January 1, 2005,
the limitation for defined benefit plans under section 415(b)(1)(B) is computed
by multiplying the participant's compensation limitation, as adjusted through
2004, by 1.0273.
The limitation for defined contribution plans under section 415(c)(1)(A) is
increased from $41,000 to $42,000.
The Code provides that various other dollar amounts are to be adjusted at the
same time and in the same manner as the dollar limitation of section
415(b)(1)(A). These dollar amounts and the adjusted amounts are as
follows:
The annual compensation limit under Sections 401(a)(17), 404(l),
408(k)(3)(C), and 408(k)(6)(D)(ii) is increased from $205,000 to $210,000.
The dollar limitation under Section 416(i)(1)(A)(i) concerning the definition
of key employee in a top-heavy plan is increased from $130,000 to $135,000.
The dollar amount under Section 409(o)(1)(C)(ii) for determining the maximum
account balance in an employee stock ownership plan subject to a 5 year
distribution period is increased from $830,000 to $850,000, while the dollar
amount used to determine the lengthening of the 5 year distribution period is
increased from $165,000 to $170,000.
The limitation used in the definition of highly compensated employee under
Section 414(q)(1)(B) is increased from $90,000 to $95,000.
The annual compensation limitation under Section 401(a)(17) for eligible
participants in certain governmental plans that, under the plan as in effect on
July 1, 1993, allowed cost of living adjustments to the compensation limitation
under the plan under Section 401(a)(17) to be taken into account, is increased
from $305,000 to $315,000.
The compensation amount under Section 408(k)(2)(C) regarding simplified
employee pensions (SEPs) remains unchanged at $450.
The compensation amounts under Section 1.61 21(f)(5)(i) of the Income Tax
Regulations concerning the definition of "control employee" for fringe benefit
valuation purposes increased from $80,000 to $85,000. The compensation amount
under Section 1.61 21(f)(5)(iii) is increased from $165,000 to $170,000.
Limitations specified by statute
The Code, as amended by the Economic Growth and Tax Relief Act of 2001 (EGTRRA),
specifies the applicable dollar amount for a particular year for certain
limitations. These applicable dollar amounts are as follows:
The limitation under Section 402(g)(1) on the exclusion for elective
deferrals described in Section 402(g)(3) is increased from $13,000 to $14,000.
The limitation under Section 408(p)(2)(E) regarding SIMPLE retirement
accounts is increased from $9,000 to $10,000.
The limitation on deferrals under Section 457(e)(15) concerning deferred
compensation plans of state and local governments and tax-exempt organizations
is increased from $13,000 to $14,000.
The dollar limitation under Section 414(v)(2)(B)(i) for catch-up
contributions to an applicable employer plan other than a plan described in
Section 401(k)(11) or 408(p) for individuals aged 50 or over is increased from
$3,000 to $4,000. The dollar limitation under Section
414(v)(2)(B)(ii) for catch-up contributions to an applicable employer plan
described in Section 401(k)(11) or 408(p) for individuals aged 50 or over is
increased from $1,500 to $2,000.
Administrators of defined benefit or defined contribution plans that have
received favorable determination letters should not request new determination
letters solely because of yearly amendments to adjust maximum limitations in the
plans.
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