Comments on: Followup: Multiple Employers and the 415(c) Limit http://www.fivecentnickel.com/2007/05/30/followup-multiple-employers-and-the-415c-limit/ personal finance tips, tricks, and commentary Sun, 22 Nov 2009 03:39:46 -0500 http://wordpress.org/?v=abc hourly 1 By: JT http://www.fivecentnickel.com/2007/05/30/followup-multiple-employers-and-the-415c-limit/comment-page-1/#comment-113753 JT Wed, 12 Dec 2007 18:35:56 +0000 http://www.fivecentnickel.com/2007/05/30/followup-multiple-employers-and-the-415c-limit/#comment-113753 This publication from the IRS did a lot to clear the issue up for me: http://www.irs.gov/pub/irs-pdf/p571.pdf It says that if you have a 403b and a 401k with the SAME employer you're in luck. You can contribute up to the 415 limit for EACH. However, and this seems to be the far more common case, if the 403b and the 401k, etc. are with different employers, including yourself, you have to aggregate the contributions so you're limited to the normal 415 limit. This has some good examples, also from the IRS: http://www.irs.gov/pub/irs-tege/pub4482.pdf It even addresses those 403b plans with mandatory contributions. This publication from the IRS did a lot to clear the issue up for me: http://www.irs.gov/pub/irs-pdf/p571.pdf

It says that if you have a 403b and a 401k with the SAME employer you’re in luck. You can contribute up to the 415 limit for EACH. However, and this seems to be the far more common case, if the 403b and the 401k, etc. are with different employers, including yourself, you have to aggregate the contributions so you’re limited to the normal 415 limit.
This has some good examples, also from the IRS: http://www.irs.gov/pub/irs-tege/pub4482.pdf
It even addresses those 403b plans with mandatory contributions.

]]> By: Doug http://www.fivecentnickel.com/2007/05/30/followup-multiple-employers-and-the-415c-limit/comment-page-1/#comment-113669 Doug Fri, 07 Dec 2007 17:23:27 +0000 http://www.fivecentnickel.com/2007/05/30/followup-multiple-employers-and-the-415c-limit/#comment-113669 I have this precise problem. My employer (a university) offers a 403(b) where my contributions are mandatory (just like what you described), a pre-tax TDA (which also falls under 403(b)), and a 457. I have separate consulting income that I put into a SEP-IRA. 2 questions: 1. I assume (as did you) that my 403(b) mandatory contributions are not "elective deferrals" such that it does not count towards the 15,500 402(g) limit. Did you ever get any resolution on that? 2. My real concern is whether 415(c) applies to my SEP contributions. I'm not sure I follow your conclusion that a University employer 403(b) would be aggregated with my self-employed SEP-IRA for 415(c) purposes. Do you have an email address that I can contact you at? I have this precise problem. My employer (a university) offers a 403(b) where my contributions are mandatory (just like what you described), a pre-tax TDA (which also falls under 403(b)), and a 457. I have separate consulting income that I put into a SEP-IRA.

2 questions:

1. I assume (as did you) that my 403(b) mandatory contributions are not “elective deferrals” such that it does not count towards the 15,500 402(g) limit. Did you ever get any resolution on that?

2. My real concern is whether 415(c) applies to my SEP contributions. I’m not sure I follow your conclusion that a University employer 403(b) would be aggregated with my self-employed SEP-IRA for 415(c) purposes.

Do you have an email address that I can contact you at?

]]> By: Jen http://www.fivecentnickel.com/2007/05/30/followup-multiple-employers-and-the-415c-limit/comment-page-1/#comment-109396 Jen Mon, 12 Nov 2007 16:16:27 +0000 http://www.fivecentnickel.com/2007/05/30/followup-multiple-employers-and-the-415c-limit/#comment-109396 Maybe you could help me with the following: I have a 403b with one employer (a DCP with a match and a TSA that I max out with $15,500) which I understand is subject to the $45,000 limit (2007). However, due to life changes I may be moving in July and thus switching employers to one that has a 401k with a match option within the same tax year. Are they treated separately under 415 code? Is the max on each (403b, 401k) $46,000 for 2008, or $46,000 for both? My current employer thinks it's separate because of the different tax codes, but I'd like to confirm so I may optimize my contributions for next year (and have to request before December 1 this year...) Thanks. Maybe you could help me with the following:
I have a 403b with one employer (a DCP with a match and a TSA that I max out with $15,500) which I understand is subject to the $45,000 limit (2007).
However, due to life changes I may be moving in July and thus switching employers to one that has a 401k with a match option within the same tax year.
Are they treated separately under 415 code? Is the max on each (403b, 401k) $46,000 for 2008, or $46,000 for both? My current employer thinks it’s separate because of the different tax codes, but I’d like to confirm so I may optimize my contributions for next year (and have to request before December 1 this year…) Thanks.

]]> By: nickel http://www.fivecentnickel.com/2007/05/30/followup-multiple-employers-and-the-415c-limit/comment-page-1/#comment-77902 nickel Wed, 30 May 2007 15:16:08 +0000 http://www.fivecentnickel.com/2007/05/30/followup-multiple-employers-and-the-415c-limit/#comment-77902 Blaine: That depends on how much self-employment income we generate this year (SEP contributions are limited to ca. 20% of self employment income). However, my intention is to max out everything up to the allowable limits. Blaine: That depends on how much self-employment income we generate this year (SEP contributions are limited to ca. 20% of self employment income). However, my intention is to max out everything up to the allowable limits.

]]> By: Blaine Moore http://www.fivecentnickel.com/2007/05/30/followup-multiple-employers-and-the-415c-limit/comment-page-1/#comment-77901 Blaine Moore Wed, 30 May 2007 14:43:24 +0000 http://www.fivecentnickel.com/2007/05/30/followup-multiple-employers-and-the-415c-limit/#comment-77901 Now that you have a better handle on how much you can save, about how much do you expect that you actually will be able to? Now that you have a better handle on how much you can save, about how much do you expect that you actually will be able to?

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