CYCLE A Submission Period – 02/01/2016 – 01/31/2017

Employee                                                  Explanation No. 6

                                                          Limitations on 
Benefit
                                                          Contributions 

Plans                                                     and Benefits 
                                                          The purpose of Form 8384, Worksheet Number 6, is to assist in de-
                                                          termining if a plan meets the major requirements of §415. However, 
                                                          there may be §415 issues not mentioned in the worksheet that could 
Note:                                                     affect the plan’s qualification. 
Plans submitted during the Cycle A submission period      Generally, a “Yes” answer to a question on the worksheet indicates a 
must satisfy the applicable changes in plan qualification favorable conclusion while a “No” answer signals a problem concern-
                                                          ing plan qualification. This rule may be altered by specific instructions 
requirements listed in Section IV of Notice 2015-84,      for a given question. Please explain any “No” answer in the “Com-
2015-52 I.R.B. 1 (the 2015 Cumulative List).              ments” section of the worksheet. 
                                                          In order for a plan to qualify, it must preclude the possibility that the 
                                                          §415 limitations will be exceeded; that is, the plan must preclude the 
This publication contains copies of:                      possibility that annual additions (under a defined contribution plan) or 
Form 8384, Worksheet 6                                    distributions (under a defined benefit plan) will exceed the limitations.  
Form 6044, Deficiency Checksheet 6                        Also, a defined benefit plan (other than a plan that is not subject to the 
                                                          requirements of §411, such as a governmental or nonelecting church 
These forms are included as examples only                 plan) must  preclude the possibility  that  an accrual will exceed the 
and should not be completed and returned                  §415 limitations.  However, no specific plan language is prescribed to 
to the Internal Revenue Service                           comply with §415. For example, if Plan X, which is a money purchase 
                                                          plan, has (1) a contribution formula of 100 percent of compensation 
                                                          actually paid or made available, as defined in §1.415(c)-2 of the regu-
                                                          lations, or $40,000 (as adjusted under §415(d)), whichever is less; (2) 
                                                          does not allow employee contributions; (3) allocates employer con-
                                                          tributions every year; and (4) uses all forfeitures to reduce employer 
                                                          contributions, then no other provisions are necessary with respect to 
                                                          §415 as long as Plan X is the only plan maintained, or that has ever 
                                                          been maintained, by the employer.
                                                          A plan will not fail to meet the definitely determinable benefit or defi-
                                                          nite predetermined allocation formula requirement merely because it 
                                                          incorporates the limitations of §415 by reference. However, if a limita-
                                                          tion of §415 may be applied in more than one manner, the plan must 
                                                          specify the manner in which the limitation is to be applied instead of 
                                                          incorporating the limitation by reference, unless a statutory or regula-
                                                          tory default rule exists. If a default rule exists, in order to deviate from 
                                                          the default rule the plan must specify the manner in which the limita-
                                                          tion is to be applied, as well as generally incorporating the limitations 
                                                          of §415 by reference.  Also see the latest revision of the EP Deter-
                                                          minations Quality Assurance Bulletin (QAB FY-2010 No.2) regarding 
                                                          Code sections that may be incorporated by reference.   
                                                          This explanation reflects changes to the limitations of §415 made by 
                                                          the Economic Growth and Tax Relief Reconciliation Act of 2001 (EG-
                                                          TRRA), the Pension Funding Equity Act of 2004 (PFEA ‘04), the Pen-
                                                          sion Protection Act of 2006 (PPA ‘06), the Worker, Retiree, and Em-
                                                          ployer Recovery Act of 2008 (WRERA) and the final regulations under 
                                                          §415. The final regulations under §415 generally apply for limitation 
                                                          years beginning on or after July 1, 2007, that is, for calendar year 
                                                          limitation years, the 2008 limitation year.  A special grandfather rule 
                                                          discussed later in this explanation applies to defined benefit plans.  
                                                          The sections cited at the end of each line explanation are to the Inter-
                                                          nal Revenue Code and the Income Tax Regulations, unless otherwise 
                                                          specified. 

                                                          The technical principles in this publication may be changed 
                                                          by future regulations or guidelines.

Publication 7001 (Rev. 4-2016)  Catalog Number 48250U  Department of the Treasury  Internal Revenue Service  www.irs.gov

Page 2                                              CYCLE A Submission Period – 02/01/2016 – 01/31/2017

I. General Definitions

Line a.  If the plan does not define the limitation year, it is deemed to use the calendar year and this question should be answered “N/A”.  
A different 12-month period may be designated in the plan or an amendment to the plan. Any change to the limitation year may only be 
made through an amendment to the plan and only to a 12-month period commencing within the current limitation year. This will create a 
short limitation year which must be separately tested for §415 purposes. If the plan is a defined contribution plan, and the limitation year is 
changed, the dollar limitation with respect to the short limitation year is determined by multiplying (A) the applicable dollar limitation for the 
calendar year in which the short limitation year ends by (B) a fraction, the numerator of which is the number of months (including fractional 
months) in the short limitation year, and the denominator of which is twelve (see Explanation No. 6 line II.b). In general, the compensation 
limitation would be determined by considering only the compensation paid or made available during the short limitation year. If a defined 
contribution plan is terminated, this also creates a short limitation year requiring the same adjustments of the limitations. A defined benefit 
plan does not have to make any special adjustments to the dollar limitation for a short limitation year with regard to the accrual of benefits.

If the employer (or the controlled group, if applicable) maintains multiple defined contribution plans with different limitation years, each 
plan must satisfy the limitations in effect for that plan for that plan’s limitation year taking into account the participant’s annual additions 
under the plan as well as the participant’s annual additions under all the other plans required to be aggregated with the plan that would 
be counted under the plan for the limitation year if they had been credited under the plan. If the employer (or the controlled group, if 
applicable) maintains multiple defined benefit plans with different limitation years, each plan must satisfy the limitations in effect for that 
plan for that plan’s limitation year taking into account the participant’s annual benefit under all the plans required to be aggregated.  See 
II.e. and III.k., below.
1.415(j)-1 

Line b. Section 415 (c)(3) compensation is required for purposes of applying the limitations of §415. The following items are includable 
in compensation for purposes of §415: (a) wages, salaries, fees for professional services and other amounts received (whether or not in 
cash) for personal services actually rendered in the course of employment with an employer maintaining the plan to the extent includible 
in gross income (including but not limited to commissions paid salesmen, compensation for service on the basis of a percentage of profits, 
commissions on insurance premiums, tips, bonuses, fringe benefits, and reimbursements or expense allowances under a nonaccount           -
able plan (as described in Regs. §1.62-2(c); (b) earned income (with respect to employees within the meaning of §401(c)(1)); (c) amounts 
described in §§104(a)(3), 105(a) and 105(h) but only to the extent they are includible in the employee’s gross income; (d) amounts paid 
or reimbursed by the employer for moving expenses incurred by the employee to the extent that such amounts are not deductible under 
§217; (e) the value of a nonstatutory option (i.e., an option not described in §1.421-1(b)) granted to an employee by the employer to the 
extent the value is includible in the employee’s gross income; (f) the amount includible in the employee’s gross income upon making the 
election in §83(b); (g) amounts includible in gross income under §409A or §457(f)(1)(A) or because of constructive receipt, and (h) differ-
ential wage payments as defined in §3401(h)(2) for years beginning after December 31, 2008. 

For purposes of (a) and (b) above in this Line b., compensation includes foreign earned income (as defined in §911(b)), whether or not ex-
cludable from gross income under §911. Compensation under (a) and (b) above is also to be determined without regard to the exclusions 
from gross income in §§872, 893, 894, 931 and 933. A plan may provide that compensation that is excludable from gross income under 
the aforementioned sections and that is not effectively connected with a trade or business in the U.S. will not be treated as compensation 
with respect to nonresident aliens who do not participate in the plan, provided the rule applies uniformly. (This is a rule of administrative 
convenience that is relevant in the determination of who is a key employee for purposes of the top-heavy rules of §416 and who is a highly 
compensated employee within the meaning of §414(q)).

The following items are excludable from compensation for purposes of §415: (a) contributions (other than elective contributions described 
in §§402(e)(3), 408(k)(6), 408(p)(2)(A)(i), or §457(b)) made by the employer to a plan of deferred compensation (including a simplified 
employee pension described in §408(k) or a simple retirement account described in §408(p), and whether or not qualified) to the extent 
that the contributions are not includible in the gross income of the employee for the taxable year in which contributed; (b) distributions from 
a plan of deferred compensation (whether or not qualified), except, a plan may provide that distributions from an unfunded nonqualified 
plan are included for §415 when the distributions are includible in income; (c) amounts realized from the exercise of a nonstatutory option, 
or when restricted stock (or property) held by an employee either becomes freely transferable or is no longer subject to a substantial risk of 
forfeiture; (d) amounts realized from the sale, exchange or other disposition of stock acquired under a statutory stock option (as defined in 
§1.421-1(b)); (e) other amounts which receive special tax benefits, such as premiums for group term life insurance (to the extent the pre-
miums are not includible and are not salary reduction amounts under §125); and (f) other items of remuneration similar to (a) through (e).

Compensation, for §415 purposes, includes any amount which is contributed or deferred by the employer at the election of the employ-
ee and which is not includible in the gross income of the employee by reason of §§125(a), 132(f)(4) , 402(e)(3), 402(h)(1)(B), 402(k) or 
457(b). A plan may provide that amounts under §125 include any amounts excludable under §106 that are not available to a participant in 
cash in lieu of group health coverage because the participant is unable to certify that he or she has other health coverage (deemed §125 
compensation). An amount will be treated as an amount under §125 only if the employer does not request or collect information regarding 
the participant’s other health coverage as part of the enrollment process for the health plan. 

The plan may adopt a safe harbor definition of §415 compensation by using either simplified compensation, §3401(a) wages, or income 
reported under §6041, §6051 and §6052.

The safe harbor definition under “simplified compensation” includes only those items specified as includable under (a), (b), and (h) of the 

Page 3                                                                         CYCLE A Submission Period – 02/01/2016 – 01/31/2017
first paragraph of this Line b and excludes all those items listed as “excludable.”  See above.

The safe harbor definition under “§3401(a) wages” includes wages within the meaning of §3401(a) (for purposes of income tax withhold      -
ing at the source), plus amounts that would be included in wages but for an election under §§125(a), 132(f)(4), 402(e)(3), 402(h)(1)(B), 
402(k), or 457(b). 

The safe harbor definition under “Information required to be reported under §§6041, 6051 and 6052”. includes “§3401(a) wages plus all 
other payments of compensation to an employee by his employer (in the course of the employer’s trade or business) for which the employ-
er is required to furnish the employee a written statement under §§6041(d), 6051(a)(3), and 6052. This safe harbor definition of compen   -
sation may be modified to exclude amounts paid or reimbursed by the employer for moving expenses incurred by an employee, but only 
to the extent that, at the time of the payment, it is reasonable to believe that these amounts are deductible by the employee under §217.

The plan may also use its §415 definition of compensation to determine its benefit formula or contribution rate. Regardless of what defini-
tion of compensation the plan uses for other purposes, to answer this question “Yes” the definition of compensation used to apply the §415 
limitations must preclude the possibility that these limitations will be exceeded. Therefore, if the plan does not use a safe harbor definition 
of compensation described above in applying the §415 limitations but instead uses a definition of compensation that may include one of 
the exclusions stated in the regulatory definition, the plan fails to meet this requirement. On the other hand, a plan does not fail to meet 
this requirement merely because it fails to include in its definition of compensation some of the items mentioned above. 
 
Except as provided below, in determining compensation for the limitation year, the plan must use compensation actually paid or made 
available (or, if earlier, includible in gross income) in such year. The plan may provide that compensation also includes amounts earned 
but not paid in a year because of the timing of pay periods if the amounts are paid in the first few weeks of the next year, the amounts 
are included uniformly and consistently for similarly situated employees, and amounts are not included in more than one limitation year.
 
As a general rule, post-severance compensation paid in a limitation year may not be treated as §415 compensation unless it is paid (or 
treated as paid) prior to the employee’s severance from employment. However, §1.415(c)-2(e)(3)(i) and (ii) of the regulations, effective 
July 1, 2007,  requires certain post-severance compensation to be included as §415 compensation while other post-severance compen-
sation may optionally be included if the plan so provides.  Post-severance compensation must be included if (a) the compensation is paid 
by the later of (1) 2 ½ months after severance from employment, or (2) the end of the limitation year that includes the date of severance 
from employment; and (b) absent a severance from employment, the compensation would have been paid to the employee while the 
employee continued in employment with the employer as regular compensation for services rendered during the employee’s regular 
working hours or as compensation for services outside the employee’s regular working hours (such as overtime or shift differential), com-
missions, bonuses or other similar compensation. A plan may optionally provide that compensation for purposes of §415 also includes 
post-severance compensation that is paid by the later of (1) 2 ½  months after an employee’s severance from employment or (2) the end 
of the limitation year that includes the date of the employee’s severance from employment if (a) the payment is for unused accrued bona 
fide sick, vacation or other leave that the employee would have been able to use if employment had continued; or (b) the payment is 
received by the employee pursuant to a nonqualified unfunded deferred compensation plan and would have been paid at the same time 
if employment had continued, but only to the extent includible in gross income.

Any payments not described above are not considered compensation if paid after severance from employment (even if they are paid by 
the later of  2 ½ months following severance from employment or the end of the limitation year that includes the date of severance) except 
for salary continuation payments to a participant who is permanently and totally disabled within the meaning of §22(e)(3), provided the 
participant was not highly compensated immediately before becoming disabled or salary continuation applies to all participants who are 
permanently and totally disabled for a fixed or determinable period. 

Back pay is treated as compensation for the limitation year to which the back pay relates to the extent the back pay represents wages and 
other compensation that would be includible in compensation for purposes of §415. 

For limitation years beginning on or after July 1, 2007, a plan’s definition of compensation for a year that is used for purposes of §415 may 
not reflect compensation for a year greater than the limit under §401(a)(17) that applies to that year. 

If an employee is employed by two or more members of a controlled group of corporations, compensation for such employee includes 
compensation from all the employers in the controlled group whether or not they maintain the plan. This also applies to compensation 
from two or more members of commonly controlled trades or businesses and affiliated service groups. 

In the case of an annuity contract described in §403(b) the term “participant’s compensation” for purposes of §415 means includible com-
pensation determined under §403(b). If a §403(b) annuity contract is aggregated with a qualified plan maintained by an employer that is 
controlled by a participant on whose behalf the contract was purchased, the total compensation from both employers is taken into account 
in applying the limitations of Part II of this explanation to the plan and contract on an aggregate basis.
415(c)(3) 
1.415(c)-2 

Line c. For plans that are sponsored by Indian tribal governments, effective for taxable years ending on or after November 15, 2013, 
proposed regulations clarify that compensation received by Indian tribal members for services rendered in performed certain fishing 
rights-related activities may be treated as compensation for purposes of applying §415 limitations, even though these payments might 
otherwise be excludible from gross income.  Various Federal statutes, treaties, executive orders regulate Indian tribal rights the right to 

Page 4                                                                    CYCLE A Submission Period – 02/01/2016 – 01/31/2017
conduct fishing activities, both on and off reservations, and income derived from these activities is exempt from income and employment 
taxes. These regulations clarify that exemption notwithstanding, fishing rights-related income is included in §415 compensation, and 
amounts may be contributed to a qualified retirement plan based on this income as a “pensionable” source.  (This clarification was nec        -
essary because as fishing rights-related income is not subject to income or employment taxes, there had been questions as to whether 
this income is included as compensation for §415 purposes.)

Under these regulations, Fishing rights-related activity with respect to Indian tribes includes any activity directly related to (a) harvesting, 
processing or transporting fish harvested in the exercise of a recognized fishing right of the tribe; or (b) selling such fish but only if sub-
stantially all of such harvesting was performed by members of such tribe.

For Cycle E, application of these proposed regulations to plans is optional, but plans can apply them currently.  A plan’s definition of com  -
pensation for §415 purposes must be administrable consistent with this change.  To the extent that a plan incorporates its §415 compen-
sation definition by reference, no change would be required.  However, plans which enumerate the various components includible in any 
of the alternative definitions would require amendment to add this additional component for taxable years ending on or after November 
15, 2013.
Prop. Reg. 1.415(c)–2(g)(9)

II. Limitations On Contributions 

Line a. Annual additions include (a) employer contributions, (b) employee contributions, and (c) forfeitures credited to a participant’s 
account for any limitation year. Elective contributions and employee and matching contributions subject to the requirements of §401(m) 
are annual additions regardless of whether they result in excess aggregate contributions, even if such excesses are corrected through 
distribution or recharacterization. Catch-up contributions under §414(v), on the other hand, are not annual additions. Excess deferrals 
that are distributed in accordance with Regs. §1.402(g)-1(e)(2) or (3) also are not annual additions. Amounts allocated to an individual 
medical account, as defined in §415(l)(2), which is part of a pension or annuity plan maintained by the employer, and amounts attributable 
to post-retirement medical benefits allocated to the account of a key employee, as defined in §419A(d)(3), under a welfare benefit fund, 
as defined in §419(e), maintained by the employer are treated as annual additions to a defined contribution plan. However, the percentage 
of compensation limitation described in line II.b. does not apply to such amounts. Annual additions under a §403(b) annuity contract also 
are treated as annual additions to a defined contribution plan.
 
Repayment by an employee of a cash-out or previously withdrawn mandatory contributions which result in the restoration of amounts that 
were forfeited because of these distributions are not annual additions. Similarly, transfers of employer or employee contributions from 
another qualified plan, repayments of loans, or rollovers accepted by the plan are not annual additions. Also, payments made to restore 
losses to a plan resulting from actions by a fiduciary for which there is a reasonable risk of liability under Title I of ERISA or under other 
federal or state law are not annual additions if similarly situated plan participants are treated similarly with respect to payments. The reg-
ulations describe other amounts which are not annual additions and some amounts which are considered annual additions for limitation 
years other than the limitation year in which actually credited to the participant’s account. These regulations should be consulted to de-
termine whether the plan correctly treats such amounts as annual additions. Generally, amounts are credited to a participant’s account if 
they are allocated to the account under the terms of the plan as of any date within the limitation year unless such allocation is dependent 
upon participation in the plan as of any time after such allocation date.
415(c);
415(l);
419A(d)(2) and (3);
419(e)
1.415(c)-1

Line b. A defined contribution plan must preclude the possibility that annual additions credited to any participant’s account in a limitation 
year will exceed the limitations of §415.  For limitation years beginning after December 31, 2001, the limitation is the lesser of $40,000 or 
100% of compensation. The $40,000 figure will be adjusted annually by the Secretary for increases in the cost of living, with references to 
quarters and base periods, independently of the defined benefit dollar limit. Any adjustments will be in $1000 increments. A defined con      -
tribution plan may provide for an automatic increase in the dollar limitation to reflect cost-of-living increases, but is not required to do so. A 
new plan may use the dollar limitation in effect for its first limitation year and adjust the limit from that point. For limitation years beginning 
on or after July 1, 2007, a plan’s definition of compensation for a year that is used for purposes of §415 may not reflect compensation for 
a year greater than the limit under §401(a)(17) that applies to that year.

Alternative limits apply to annual additions under a §403(b) annuity contract for a participant who is an employee of a church or a con-
vention or association of churches.  These alternative limits permit minimum annual additions of up to $10,000 for a limitation year, not 
to exceed $40,000 for all limitation years, regardless of the general limits.  A separate rule permits a $3,000 minimum annual addition for 
church employees who are foreign missionaries and whose adjusted gross income does not exceed $17,000.  The regulations should be 
consulted regarding the interaction of these two minimums. 

If you are reviewing a defined benefit plan that provides for employee contributions (whether mandatory or voluntary), such employee 
contributions are treated as a separate defined contribution plan for §415 purposes. Therefore such employee contributions must comply 
with this limitation requirement. 
415(c)(1);
415(d)(1);

Page 5                                                                            CYCLE A Submission Period – 02/01/2016 – 01/31/2017
415(d)(3);
415(d)(4);
1.415(c)-1 

Line c. The regulations under §415 that were in effect for limitation years beginning before July 1, 2007 (the 1981 regulations) set forth 
permitted correction methods for excess annual additions that arose under certain circumstances.  See II.c. of the version of this expla-
nation, rev. 3-2006, for an explanation of the correction methods.  The correction methods under the 1981 regulations have been deleted 
in the final regulations, effective for limitation years beginning on or after July 1, 2007. Correction of excess annual additions is generally 
only permitted under the Employee Plans Compliance Resolution System (EPCRS) under Rev. Proc. 2013-12, 2013-04 I.R.B. 313.  If 
the plan contains the correction methods of the 1981 regulations, the plan must limit the application of the methods to limitation years 
beginning before July 1, 2007. 
Preamble to Final §415 Regulations;                      
Rev. Proc. 2008-50 

Line d. A defined contribution plan may provide for contributions on behalf of a participant who has become permanently and totally dis     -
abled (as defined in §22(e)(3)) even though the participant has no actual compensation. In such cases, the disabled participant is deemed 
to have compensation each year equal to the rate of compensation paid immediately before the participant became permanently and 
totally disabled, if greater than the disabled participant’s actual compensation for the year. 

A plan may either provide for the continuation of contributions on behalf of all permanently and totally disabled participants (as defined in 
§22(e)(3)) for a fixed or determinable period or provide for the continuation of contributions only for those employees who were nonhighly 
compensated when they became disabled.

Contributions made with respect to the imputed compensation of a disabled participant must be nonforfeitable when made. 

Note that this imputed compensation rule for disabled participants is separate from the salary continuation rule for disabled participants 
described in line b above.
415(c)(3)(C);
1.415(c)-2(g)(4)

Line e. The sum of the annual additions credited to a participant’s account in any limitation year for all of the qualified defined contribution 
plans of the employer or a predecessor employer (which, for this purpose, include plans qualified under §401(a), annuity plans described 
in §403(a), and simplified employee pensions described in §408(k)), regardless of whether a plan is terminated, may not exceed the lim      -
itations of §415(c).   See line III.g. for the definition of predecessor employer.

A qualified defined contribution plan maintained by any member of a controlled group of corporations or commonly controlled trades or 
businesses (as defined in §414(b) and (c) as modified by §415(h)) or any member of an affiliated service group (as defined in §414(m)), 
is considered maintained by all of the members for this purpose. 

There are two exceptions to the foregoing plan aggregation rules that pertain to multiemployer plans, as defined in §414(f).  First, multiem-
ployer plans are not aggregated with other multiemployer plans for purposes of §415.  Second, if the employer maintains a multiemployer 
plan and that plan so provides, only the benefits (i.e., annual additions) under the multiemployer plan that are provided by the employer 
are treated as benefits (annual additions) provided under the employer’s plans that are not multiemployer plans.

A qualified defined benefit plan maintained by the employer to which employee contributions are made is considered a separate defined 
contribution plan for this purpose to the extent such employee contributions constitute annual additions in the limitation year. Also, em-
ployer contributions allocated to (1) an individual medical benefit account maintained under a pension or annuity plan or (2) the account 
of a key employee under a welfare benefit trust described in §419(e) to provide post-retirement medical benefits are treated as annual 
additions to a defined contribution plan. 

The provisions of the plans must preclude the possibility that the total annual additions allocated to any participant in all such plans will 
exceed these limitations in any limitation year whether or not the §415 limitations are incorporated by reference. Note that if the plans 
cannot have common participants, this requirement is satisfied. 

A money purchase plan may provide for the automatic freezing or reduction of contributions to insure the limitations of §415 are met with-
out violating the requirement that benefits be definitely determinable if the plan provision precludes employer discretion. 

A profit-sharing or stock bonus plan may also contain a provision for the automatic freezing or reduction of contributions without violating 
the definite predetermined allocation formula requirement if the plan provision precludes employer discretion. For example, if two defined 
contribution plans of one employer would otherwise provide for aggregate contributions exceeding the limitations of §415(c), the plan 
provisions must specify, without involving employer discretion, which plan will reduce contributions and allocations to prevent an excess 
annual addition and how the reduction will occur.

A §403(b) annuity contract is considered a plan maintained by the employee and must be aggregated when the employee is in control 
of the employer.  Effective for limitation years beginning after December 31, 2001, the special election for §403(b) annuity contracts pur-
chased by educational organizations, hospitals, home health service agencies and certain churches is eliminated.

Page 6                                                               CYCLE A Submission Period – 02/01/2016 – 01/31/2017

Also see line III.g. for additional special rules that may also apply to defined contribution plans.
415(f)(1)
415(k)(4)
1.401(a)-1(b)(1)(ii) and (iii); 1.415(a)-1(d); 1.415(c)-1; 1.415(f)-1

Ill. Limitations On Benefits - General Rule

(Note:This explanation, including this Part III, reflects the requirements of the final regulations under §415 that are effective for limitation 
years beginning on or after July 1, 2007.  A defined benefit plan is considered to satisfy the limitations of §415(b) with respect to benefits 
accrued or payable under the plan as of the end of the last limitation year beginning before July 1, 2007 under plan provisions (including a 
plan’s limitation year) that were adopted and in effect before April 5, 2007. This grandfather rule is available only if the plan provisions ad-
opted and in effect on April 5, 2007 satisfied the requirements of §415 and related published guidance in effect before the final regulations. 
See the revision of this explanation, rev. 3-2006, for an explanation of the prior guidance. A plan is not ineligible for the grandfather rule 
because the plan has not yet been amended for the changes to §415(b) made by PFEA ‘04 and PPA ‘06 or because the plan considered 
compensation in excess of the §401(a)(17) limit in applying the compensation limit described in line III.a. for limitation years before the 
final regulation effective date. See line III.b.  For a participant with grandfathered benefits, additional benefits cannot accrue after the ef-
fective date (limitation years beginning on or after July 1, 2007) of the final regulations unless and until the sum of such additional benefits 
and the participant’s grandfathered benefits satisfies the requirements of the final regulations.

Section 415(b)(2)(E)(v) of the Code was amended by §103(b)(2)(B)(i) of the WRERA, providing that the mortality table used for adjusting 
limitations (form adjustments or age adjustments) on defined benefit plans shall be the applicable mortality table within the meaning of 
§417(e)(3)(B) of the Code, which is based on mortality table under §430((h)(3)(A).

Line a. The maximum annual benefit to which any participant may be entitled during the limitation year may not exceed the lesser of 
$160,000 (effective for the first limitation year ending after December 31, 2001) or 100 percent of the participant’s average compensation 
for the three consecutive calendar years of employment (or lesser period if the employee does not have three consecutive years) which 
produce the greatest aggregate compensation. The percentage of compensation limit does not apply, however, to a governmental plan 
as defined in §414(d), a multiemployer plan as defined in §414(f), a collectively bargained plan that is described in §415(b)(7), or to a 
participant in a plan maintained by a church described in §3121(w)(3)(A) who has never been a §414(q) highly compensated employee 
of the church. 
 
A different 12-month period may be used if uniformly and consistently applied in a manner specified in the plan.  For a participant who has 
had a severance from employment and is then rehired, the years for which the participant performed no service and received no compen-
sation are ignored, and the years immediately preceding and following this break period are treated as consecutive. 

The annual benefit is a benefit payable annually as a straight life annuity. The benefits attributable to employee contributions and rollover 
contributions are not taken into account for purposes of this limitation. Social security supplements and benefits transferred from another 
defined benefit plan, other than an elective transfer of a participant’s distributable benefits, are taken into account.

The dollar limitation and the compensation limitation will be adjusted annually by the Commissioner to reflect the increase in the cost-of-
living. The increased limits apply to any limitation year ending with or within the calendar year for which the increase is effective, but a 
participant’s benefits may not reflect the adjustment prior to January 1 of that calendar year.

A plan may provide for automatic increases in the dollar and compensation limitations by incorporating by reference the annual adjust-
ments under §415(d). However, if a plan incorporates the adjustments by reference, the annual adjustment to the dollar limitation will not 
apply to a participant after a severance from employment, unless the plan so specifies. Likewise, the annual adjustment to the compen            -
sation limitation, which applies only after a participant’s severance from employment, will not apply unless the plan so specifies.  Instead 
of automatically incorporating the cost-of-living adjustments by reference, a plan may be amended from time to time to take into account 
these increases. The regulations provide two safe harbors that allow distributions that are increased pursuant to plan amendments to 
be treated as continuing to satisfy the limitations of §415(b). These safe harbor provisions of the regulations should be consulted when 
reviewing such a plan amendment. Finally, if a distribution option that is not subject to §417(e)(3), such as a QJSA, includes an auto-
matic benefit increase feature which will never cause a distribution to exceed the limitations at the annuity starting date as increased by 
the subsequent annual adjustments, the increased benefit will continue to satisfy §415(b). If a plan contains a provision for cost-of-living 
increases other than one of those described above, the cost-of-living adjustments must be taken into account under the multiple annuity 
starting date rule explained below for purposes of satisfying the limitations of §415(b).

The plan provisions must preclude the possibility that an annual benefit in excess of this limitation will be accrued or become payable at 
any time. It is not enough that no participant has actually accrued a benefit in excess of this limitation. In addition, if a participant has dis-
tributions commencing at different times (i.e., multiple annuity starting dates), the limitations must be satisfied as of each annuity starting 
date, actuarially adjusting for past and future distributions. 
415(b)(1), 415(b)(3), and 415(d)(1)
1.415(a)-1(d)(3)(v), 1.415(b)-1(b), 1.415(b)-1(c)(5), 1.415(d)-1

Line b. For limitation years beginning on or after July 1, 2007, compensation for any 12-month period taken into account in determining 

Page 7                                                           CYCLE A Submission Period – 02/01/2016 – 01/31/2017
average compensation for the high three years may not include compensation in excess of the limitation under §401(a)(17) for the cal-
endar year in which the 12-month period begins. A participant’s high 3 years shall be the period of consecutive calendar years (not more 
than 3) during which the participant had the greatest aggregate compensation from the employer. 

Under the grandfather rule described in the note preceding the explanation for line III.a., a plan that previously considered compensation 
in excess of the §401(a)(17) limit in applying the compensation limitation of line III.a. preserves the benefit previously accrued for a par    -
ticipant.
401(a)(17), 1.415(b)-1(a)(5)(I),  1.415(c)-2(f) 

Line c. If a defined benefit plan provides a retirement benefit in any form other than a straight life annuity, the plan benefit must be adjust -
ed to an actuarially equivalent straight life annuity beginning at the same age. If the form of benefit is a straight life annuity or a qualified 
joint and survivor annuity, no adjustments are necessary. Examples of benefits that are not in the form of a straight life annuity are an 
annuity with a post-retirement death benefit or a lump sum. 

In making these adjustments the following values are not taken into account: (1) the value of a qualified joint and survivor annuity to the 
extent such value exceeds the sum of (A) the value of a straight life annuity beginning on the same date and (B) the value of any post-re-
tirement death benefits payable even if the annuity was not in the qualified joint and survivor form; (2) the value of ancillary benefits not 
directly related to retirement benefits (such as pre- retirement disability and death benefits, and post- retirement medical benefits); and 
(3) the value of benefits which include an automatic benefit increase feature, provided the benefit form is not subject to the requirements 
of §417(e)(3), such as a QJSA, and the amount payable in any limitation year is limited to the limitations of §415 in effect at the annuity 
starting date as subsequently increased by the annual cost-of-living adjustments under the Code. Social Security supplements are directly 
related to retirement benefits and should be taken into account. 

The assumptions that are required to be used in adjusting the benefit depend on whether the benefit form is subject to the present value 
requirements of §417(e)(3) and when the payment commences. Benefits subject to §417(e)(3) include all forms except any annual benefit 
that (i) is nondecreasing for the life of the participant or, in the case of a QPSA, the life of the participant’s spouse; or (ii) decreases during 
the life of the participant merely because of (a) the death of the survivor annuitant (but only if the reduction is to a level not below 50% of 
the annual benefit payable before the death of the survivor annuitant) or (b) the cessation or reduction of Social Security supplements or 
qualified disability benefits (as defined in §411(a)(9)). 

Where the adjustment is based on the interest rate specified in the plan, the rate specified in the plan includes the rate used to derive 
factors specified in the plan. Of course, different interest rate assumptions may be specified to determine the actuarial equivalence of 
different forms of benefit under the plan, and in such cases, the rate specified in the plan means the rate applicable to that particular 
benefit form.
 
 (i) For limitation years beginning on or after July 1, 2007, the actuarially equivalent straight life annuity for purposes of applying the limit 
 in Ill.a. to benefits that are not subject to §417(e)(3) is equal to the greater of the annual amount of the straight life annuity (if any) pay-
 able to the participant under the plan commencing at the same annuity starting date as the other benefit form, and the annual amount of 
 the straight life annuity commencing at the same annuity starting date that has the same actuarial present value as the form of benefit 
 payable computed using a 5 percent interest rate assumption and the applicable mortality table under §417(e)(3) (that is, the table in 
 Rev. Rul. 2001-62). 

 (ii) For limitation years beginning before July 1, 2007, the actuarially equivalent straight life annuity for purposes of applying the limit in 
 Ill.a. to benefits that are not subject to §417(e)(3) is equal to the annual amount of the straight life annuity commencing at the same an-
 nuity starting date that has the same actuarial present value as the participant’s form of benefit computed using whichever of the follow      -
 ing produces the greater annual amount: (1) the interest rate and mortality table or other tabular factor specified in the plan for adjusting 
 benefits in the same form as the participant’s benefit; and (2) a 5 percent interest rate assumption and the applicable mortality table. 

Line d.  

 (i) For plan benefits subject to §417(e)(3), if the annuity starting date is in a plan year beginning after 2005, the actuarially equivalent 
 straight life annuity equals the annual amount of the straight life annuity commencing at the same annuity starting date that has the 
 same actuarial present value as the  form of benefit payable, using whichever of the following produces the greatest annual amount:  
 (1) the interest rate and the mortality table or other tabular factor specified in the plan for adjusting benefits in the same form; (2) a 5.5 
 percent interest rate assumption and the applicable mortality table; and (3) the applicable interest rate under §417(e)(3) and the appli-
 cable mortality table, divided by 1.05.

 (ii) For plan benefits subject to §417(e)(3), if the annuity starting date is in a plan year beginning in 2004 or 2005, the actuarially equiv  -
 alent straight life annuity equals the annual amount of the straight life annuity commencing at the same annuity starting date that has 
 the same actuarial present value as the  form of benefit payable, using whichever of the following produces the greater annual amount: 
 (1) the interest rate and mortality table or other tabular factor specified in the plan for adjusting benefits in the same form; and (2) 5.5 
 percent interest and the applicable mortality table.

 (iii) For plan benefits subject to §417(e)(3), if the annuity starting date is on or after the first day of the first plan year beginning in 2004 
 and before December 31, 2004, the plan may apply the transition rule described in §101(d)(3) of PFEA ’04 in lieu of the rule described 
 in the preceding paragraph to determine the amount of the participant’s benefit.  The transition rule is explained in Notice 2004-78.  

Page 8                                                                    CYCLE A Submission Period – 02/01/2016 – 01/31/2017
Section 103(a) of WRERA changed the deadline to adopt PFEA’04 amendments from the end of the 2008 plan year to the end of the 
2009 plan year.
415(b)(2)(B), 415(b)(2)(E) and 417(e)(3) 
1.415(b)-1(a), (b) and (c), 1.417(e)-1(d) 
Rev. Proc. 2008-62, 2008-2 C.B. 935,
Rev. Rul. 2001-62, 2001-2 C.B. 632
Notice 2004-78, 2004-2 C.B. 879
Reg. 1.430(h)(3)-1 

Line e. If a defined benefit plan provides a retirement benefit which begins before age 62, the dollar limitation determined under line Ill.a. 
must be adjusted (that is, reduced for early commencement). How the dollar limitation is adjusted for early commencement depends on 
whether the annuity starting date is in a limitation year beginning before July 1, 2007 or in a limitation year beginning on or after that date.  
If the annuity starting date is in a limitation year beginning on or after July 1, 2007, the adjustment that is required further depends on 
whether the plan offers an immediately commencing straight life annuity at both the age of benefit commencement and age 62. 

The adjustments described below for pre-62 benefit commencement take into account mortality in determining actuarial equivalence. 
However, to the extent the plan does not forfeit benefits upon the participant’s death before the annuity starting date, the plan does not 
have to take into account the mortality decrement for the probability of death between the annuity starting date and age 62 in determining 
actuarial equivalence for purposes of the age adjustments. If the plan does not charge participants for providing a qualified preretirement 
survivor annuity, the plan is treated as not forfeiting benefits on death.

(i) If the annuity starting date is before age 62 and occurs in a limitation year beginning before July 1, 2007, the adjusted dollar limitation 
is the annual amount of a benefit payable in the form of a straight life annuity commencing at the participant’s annuity starting date 
that is the actuarial equivalent of the dollar limitation determined under line III.a. For purposes of this adjustment, actuarial equivalence 
is computed using whichever of the following produces the smaller annual amount:  (1) the interest rate and mortality table or other 
tabular factor specified in the plan for determining actuarial equivalence for early retirement purposes; or (2) a 5 percent interest rate 
assumption and the applicable mortality table.

(ii) If the annuity starting date is before age 62 and occurs in a limitation year beginning on or after July 1, 2007, and the plan does not 
have an immediately commencing straight life annuity payable at both age 62 and the age of benefit commencement, the adjusted 
dollar limitation is also the annual amount of a benefit payable in the form of a straight life annuity commencing at the participant’s 
annuity starting date that is the actuarial equivalent of the dollar limitation determined under line III.a.  However, in this case, actuarial 
equivalence is computed without regard to the plan’s actuarial factors, using a 5 percent interest rate assumption and the applicable 
mortality table and expressing the participant’s age based on completed calendar months as of the annuity starting date.

(iii) If the annuity starting date is before age 62 and occurs in a limitation year beginning on or after July 1, 2007, and the plan has an 
immediately commencing straight life annuity payable at both age 62 and the age of benefit commencement, the adjusted dollar limita-
tion is the lesser of (1) the adjusted dollar limitation determined in accordance with the preceding paragraph; and (2) the product of the 
dollar limitation under line III.a. multiplied by the ratio of the annual amount of the immediately commencing straight life annuity under 
the plan at the participant’s annuity starting date to the annual amount of the immediately commencing straight life annuity under the 
plan at age 62, both determined without applying the limitations of §415. 
415(b)(2)(C), 415(b)(2)(E)(i) and (v)
1.415(b)-1(d)

Line f. If the plan provides a retirement benefit which begins after age 65, the plan may provide for the dollar limitation determined under 
line Ill.a. to be adjusted (that is, increased for delayed commencement), although a participant’s benefit continues to be limited to 100% 
of the participant’s high three-year compensation. How the dollar limitation is adjusted for delayed commencement depends on whether 
the annuity starting date is in a limitation year beginning before July 1, 2007 or in a limitation year beginning on or after that date.  If the 
annuity starting date is in a limitation year beginning on or after July 1, 2007, the adjustment that is required further depends on whether 
the plan offers an immediately commencing straight life annuity at both the age of benefit commencement and age 65. 

The adjustments described below for post-65 benefit commencement take into account mortality in determining actuarial equivalence. 
However, to the extent the plan does not forfeit benefits upon the participant’s death before the annuity starting date, the plan may not 
take into account the mortality decrement for the probability of death between age 65 and the annuity starting date in determining actuarial 
equivalence for purposes of the age adjustments. If the plan does not charge participants for providing a qualified preretirement survivor 
annuity, the plan is treated as not forfeiting benefits on death.

(i) If the annuity starting date is after age 65 and occurs in a limitation year beginning before July 1, 2007, the adjusted dollar limitation 
is the annual amount of a benefit payable in the form of a straight life annuity commencing at the participant’s annuity starting date that 
is the actuarial equivalent of the dollar limitation under line III.a. For purposes of this adjustment, actuarial equivalence is computed 
using whichever of the following produces the smaller annual amount:  (1) the interest rate and the mortality table or other tabular factor 
specified in the plan for determining actuarial equivalence for delayed retirement purposes; or (2) a 5 percent interest rate assumption 
and the applicable mortality table.

(ii) If the annuity starting date is after age 65 and occurs in a limitation year beginning on or after July 1, 2007, and the plan does not 
have an immediately commencing straight life annuity payable at both age 65 and the age of benefit commencement, the adjusted 

Page 9                                    CYCLE A Submission Period – 02/01/2016 – 01/31/2017
dollar limitation is also the annual amount of a benefit payable in the form of a straight life annuity commencing at the participant’s 
annuity starting date that is the actuarial equivalent of the dollar limitation determined under line III.a.  However, in this case, actuarial 
equivalence is computed without regard to the plan’s actuarial factors, using a 5 percent interest rate assumption and the applicable 
mortality table and expressing the participant’s age based on completed calendar months as of the annuity starting date.

(iii) If the annuity starting date is after age 65 and occurs in a limitation year beginning on or after July 1, 2007, and the plan has an im-
mediately commencing straight life annuity payable at both age 65 and the age of benefit commencement, the adjusted dollar limitation 
is the lesser of (1) the adjusted dollar limitation determined in accordance with the preceding paragraph; and (2) the product of the dollar 
limitation under line III.a. multiplied by the ratio of the annual amount of the adjusted immediately commencing straight life annuity under 
the plan at the participant’s annuity starting date to the annual amount of the adjusted immediately commencing straight life annuity 
under the plan at age 65, both determined without applying the limitations of this article. The adjusted immediately commencing straight 
life annuity at the participant’s annuity starting date means the annual amount of such annuity payable to the participant, computed 
without regard to the participant’s accruals after age 65 but including actuarial adjustments even if those actuarial adjustments are used 
to offset accruals; and the adjusted immediately commencing straight life annuity at age 65 means the annual amount of such annuity 
that would be payable to a hypothetical participant who is age 65 and has the same accrued benefit as the participant.
415(b)(2)(D), 415(b)(2)(E)(iii) and (V)
1.415(b)-1(e)  

Line g. Under §411, if benefits are not paid to a participant upon attainment of normal retirement age (NRA), the plan must either provide 
for the suspension of the participant’s benefit under §411(a)(3)(B) or actuarially increase the benefit for late retirement to avoid an imper-
missible forfeiture of the benefit.  If the NRA under the plan is less than 65, the requirement to actuarially increase the benefit after NRA 
could, when coupled with the fact that the §415 dollar limit is not adjusted between age 62 and age 65, cause the plan to violate §415.  
This would occur where the participant works past NRA and the benefit equals the §415 dollar limit at an age between 62 and 65.  Any 
actuarial increase after that age and prior to age 65 would violate §415.  Accordingly, if the plan’s NRA is less than 65, the plan must co-
ordinate the requirements for nonforfeitablity of benefits and actuarial increase for delayed retirement with the limits of §415.  One way to 
satisfy these requirements is to suspend the participant’s benefit as permitted under §411(a)(3)(B).  However, the prohibition on amending 
a plan to place greater restrictions or conditions on §411(d)(6) protected benefits by adding or modifying a suspension of benefits provi    -
sion may eliminate suspension as an option.  In this case, the plan must provide for the in-service payment of the participant’s benefit if 
the participant has reached NRA and the benefit cannot be actuarially increased without violating §415.
411(a)
1.411(d)-3(a)(3), 1.411(d)-3(j)(3)
Rev. Rul. 2001-51, 2001-2 C.B. 427, Q&A-4 

Line h. The annual benefit (without regard to the age at which benefits commence) payable with respect to a participant is not considered 
to exceed the otherwise applicable limitations on benefits under §415(b) if (a) the employer-derived retirement benefits under the plan 
and all other defined benefit plans of the employer do not in the aggregate exceed $10,000 for the limitation year or any prior limitation 
year, and (b) the employer has not at any time maintained a defined contribution plan in which the participant participated.  In the case of 
a multiemployer plan, the $10,000 minimum benefit rule applies regardless of whether the participant ever participated in another plan of 
the employer, provided that no such other plan was maintained as a result of collective bargaining with the same employee representative 
as the multiemployer plan.  For purposes of the special exception for total benefits not in excess of $10,000, mandatory employee con        -
tributions to a defined benefit plan, an individual medical benefits account under §401(h), and a postretirement medical benefits account 
under  §419A(d)(1) are not considered separate defined contribution plans.  Also, no upward adjustment need be made to the value of 
the retirement benefit payable under the plan if the benefit payable is not in the form of a straight life annuity. 
415(b)(4)
1.415(b)-1(f) 

Line i. The percentage of compensation limitation described in line Ill.a. and the $10,000 minimum benefit limitation in line Ill.g. must be 
reduced for a participant who begins to receive retirement benefits under the plan when the participant has less than ten years of service. 
The reduction is accomplished by multiplying the otherwise applicable limitation by the following fraction: Years of service with the em-
ployer including the current limitation year (but not less than one), divided by 10. 
For this purpose, a year of service may be determined on any reasonable and consistent basis. 
415(b)(5)(B)
1.415(b)-1(g)(2) 

Line j. The dollar limitation of III.a. is reduced for participants with less than 10 years of participation in the plan. Specifically, the dollar 
limitation is multiplied by a fraction, the numerator of which is the number of years (computed to fractional parts of a year, but not less than 
one) of participation in the defined benefit plan of the employer, and the denominator of which is 10. 

For purposes of determining a participant’s years of participation, the participant shall be credited with a year of participation (computed 
to fractional parts of a year) for each accrual computation period for which: (1) the participant is credited with at least the service required 
to accrue a benefit, and (2) the participant is included as a plan participant under the eligibility provisions of the plan for at least one day of 
the accrual computation period. If these two conditions are met, the portion of a year of participation credited to the participant shall equal 
the amount of benefit accrual service credited to the participant for such accrual computation period. For example, if under the terms of a 
plan, a participant receives 1/10 of a year of benefit accrual service for an accrual computation period for each 200 hours of service, and 
the participant is credited with 1,000 hours of service for the period, the participant is credited with 1/2 a year of participation. 

Page 10                                                                           CYCLE A Submission Period – 02/01/2016 – 01/31/2017
For purposes of determining years of participation, a participant who is permanently and totally disabled within the meaning of §415(c)(3)
(C)(i) for an accrual computation period is credited with a year of participation for that period.

The plan must be established before the end of the accrual computation period in order to credit a participant with any part of a year of 
participation for that period.
415(b)(5)(B), 1.415(b)-1(g)(1) 
1.415(b)-1(g)(1) 

Line k. All the qualified defined benefit plans ever maintained by the employer or a predecessor employer (whether or not such plans are 
terminated) are treated as one defined benefit plan for purposes of the limitations under §415(b). For this purpose, a qualified defined 
benefit plan maintained by any member of a controlled group of corporations or commonly controlled trades or businesses (as defined in 
§§414(b) and (c) as modified by §415(h)), or any member of an affiliated service group (as defined in §414(m)), is considered maintained 
by all the members.  If the employer maintains a plan that provides a benefit which the participant accrued while performing services for a 
former employer, the former employer is a predecessor employer with respect to the participant in the plan.  A former entity that antedates 
the employer is also a predecessor employer with respect to a participant if, under the facts and circumstances, the employer constitutes 
a continuation of all or a portion of the trade or business of the former entity. 

There are three exceptions to the foregoing plan aggregation rules that pertain to multiemployer plans, as defined in §414(f).  First, mul       -
tiemployer plans are not aggregated with other multiemployer plans for purposes of §415.  Second, if the employer maintains a multiem-
ployer plan and that plan so provides, only the benefits under the multiemployer plan that are provided by the employer are treated as 
benefits provided under the employer’s plans that are not multiemployer plans.  Third, a multiemployer plan is disregarded for purposes 
of applying the percentage of compensation limitation under lines III.a. and III.h. to a plan which is not a multiemployer plan.  

The final regulations contain rules for determining the benefit to be taken into account in the case of plan termination or transfer of benefits 
to another plan, where a plan ceases to be affiliated and aggregated with the employer’s plan under line III.j. because of the break-up of 
the §414(b), (c) or (m) group, and with respect to the situation where the employer maintains a plan under which a participant accrued a 
benefit while performing services for a predecessor employer.

Plan termination – If the plan terminates with sufficient assets for the payment of all benefit liabilities and a participant has not yet com-
menced benefits, the benefits taken into account for §415 purposes are the benefits provided pursuant to the annuities purchased to pro          -
vide the participant’s benefits at each possible annuity starting date.  If there are insufficient assets for the payment of all benefit liabilities, 
the benefits taken into account are the benefits that are actually provided to the participant.  

Benefits transferred to another plan - If a participant’s benefits are transferred to another defined benefit plan of the employer and the 
transfer is not a transfer of distributable benefits pursuant to §1.411(d)-4, Q&A-3(c), of the regulations, the transferred benefits are not 
treated as being provided under the transferor plan (but are taken into account as benefits provided under the transferee plan).  If a par-
ticipant’s benefits are transferred to another defined benefit plan that is not maintained by the employer and the transfer is not a transfer 
of distributable benefits, the transferred benefits are treated by the employer’s plan as if such benefits were provided under annuities 
purchased to provide benefits under a plan of the employer that terminated immediately prior to the transfer with sufficient assets to pay 
all benefit liabilities.  In the case of a transfer of distributable benefits, the amount transferred is treated as a benefit paid from the trans-
feror plan. 

Cessation of affiliation because of break-up of the §414(b), (c) or (m) group – The formerly affiliated plan continues to be treated as a plan 
of the employer, but it is treated as if it had terminated immediately prior to the cessation of affiliation (e.g., the sale of a member of the 
group outside the group or the transfer of plan sponsorship outside the group) with sufficient assets to pay participants’ benefit liabilities 
under the plan and had purchased annuities to provide benefits. 

Plan maintained by successor employer - If the employer maintains a defined benefit plan that provides benefits accrued by a participant 
while performing services for a predecessor employer, the participant’s benefits under any plan maintained by the predecessor employer 
are treated as provided under a plan maintained by the employer.  However, for this purpose, the plan of the predecessor employer is 
treated as if it had terminated immediately prior to the event giving rise to the predecessor employer relationship (such as transfer of 
benefits or plan sponsorship) with sufficient assets to pay participants’ benefit liabilities under the plan, and had purchased annuities to 
provide benefits; the employer and the predecessor employer shall be treated as if they were a single e 
mployer immediately prior to such event and as unrelated employers immediately after the event; and if the event giving rise to the pre-
decessor relationship is a benefit transfer, the transferred benefits shall be excluded in determining the benefits provide under the plan 
of the predecessor employer. 
The provisions in the plans must preclude the possibility that the total annual benefit payable to any participant under all defined benefit 
plans maintained by the employer or a predecessor employer will exceed these limitations whether or not the §415 limitations are incor-
porated by reference. The use of a plan provision which automatically freezes or reduces the rate of benefit accrual to insure that these 
limitations are not exceeded will not violate the requirement that benefits must be definitely determinable if the plan provision precludes 
employer discretion. Note that if the plans cannot have common participants, this requirement is satisfied. 
415(f)(1)(A) 
1.415(a)-1(d)(1)
1.415(f)-1

                                                                     CYCLE A Submission Period – 02/01/2016 – 01/31/2017
                        Employee Plan Deficiency Checksheet
                          Attachment Number 6
                        Limitations on Contributions and Benefits
For IRS Use             Please furnish the amendment(s) requested in the section(s) checked below.
     601    Section        of the plan must define the term "limitation year." If not, the plan's limitation year is the 
     I.a.   calendar year. Regs. § 1.415(j)-1. 
     602    Section        of the plan should be amended to define the term "compensation" in accordance with IRC § 
     I.b.   415(c)(3) and § 1.415(c)-2 of the regulations.
     603    Section        of the plan should be amended to define annual additions in accordance with the Code and 
     II.a.  regulations. IRC § 415(c), 415(l), 419A (d)(2) and (3), 419(e), and Regs. § 1.415(c)-1.
     604    Section        of the plan must preclude the possibility that the annual additions to any participant's account 
     II.b.  for a limitation year will exceed the lesser of 100 percent of compensation or $40,000, as adjusted for cost-of-
            living increases pursuant to IRC § 415(c)(1), 415(d)(1), 415(d)(3), and 415(d)(4), and Regs. § 1.415(c)-1. 
     605    Section        of the plan may provide for the use of one of the methods set forth in §1.415-6(b)(6) of the 
     II.c.  1981 regulations only with respect to limitation years beginning before July 1, 2007, and only in situations where 
            excess annual additions may result from contributions based on estimated annual compensation, the allocation 
            of forfeitures, or a reasonable error in determining the amount of elective deferrals under § 402(g)(3). Regs. § 
            1.401(a)-2(b), § 1.415-6(b)(6) of the 1981 regulations.
     606    Where a defined contribution plan provides for an employer to continue to make contributions on behalf of an 
     II.d.  employee who is permanently and totally disabled (as defined in § 22(e)(3) of the Code), then the imputed 
            compensation upon which contributions are made must be no greater than the rate at which the participant was 
            paid immediately before becoming permanently and totally disabled. A plan may provide for the continuation of 
            contributions on behalf of all such disabled participants for a fixed or determinable period or only on behalf of 
            those employees who were nonhighly compensated when they became disabled. Such contributions must be 
            nonforfeitable when made. Section              of the plan should be amended accordingly. IRC § 415(c)(3)(C) 
            and Regs. § 1.415(c)-2(g)(4).
     607    Except as provided in this paragraph with respect to multiemployer plans (as defined in § 414(f)), section 
     II.e.               of the plan must provide that all defined contribution plans (including voluntary employee contribution 
            accounts in a defined benefit plan, mandatory contributions to a defined benefit plan, individual medical benefit 
            accounts under § 401(h), key employee accounts under a welfare benefit plan described in § 419, and simplified 
            employee pensions under § 408(k)) of the employer or a predecessor employer, whether or not terminated, will 
            be treated as one defined contribution plan for purposes of the limitations under § 415(c). Otherwise each of the 
            defined contribution plans must contain provisions which limit each plan, without involving employer discretion, 
            such that the possibility is precluded that the aggregated defined contribution plans may exceed the limitations 
            of § 415(c). Where the employer is a member of a controlled group of corporations or commonly controlled 
            trades or businesses, or a member of an affiliated service group, within the meaning of § 414(b), (c) or (m) and 
            415(g) and (h), the plan must provide that all such employers are treated as a single employer for purposes of 
            the plan's application of the § 415 limitations. Notwithstanding the preceding, multiemployer plans are not 
            aggregated with other multiemployer plans for purposes of § 415. IRC § 419, 415(f)(1) and (k)(4); Regs. § 1.415
            (a)-1(d), 1.415(c)-1, 1.415(f)(1), and 1.401(a)-1(b)(1)(iii).
     608    Section        of the plan must provide that the annual benefit to which any participant may be entitled, in 
     III.a. the form of a straight life annuity, shall not exceed the lesser of $160,000 or 100 percent of the participant's high 
            three year average compensation (or fewer, if the employee does not have three consecutive years). The 
            percentage of compensation limit does not apply, however, if the plan is a governmental plan (as defined in § 
            414(d)), a multiemployer plan (as defined in § 414(f)), or a collectively bargained plan that is described in § 415
            (b)(7), and does not apply to a participant in a plan maintained by a church described in § 3121(w)(3)(A) who 
            has never been a § 414(q) highly compensated employee of the church. If a participant has distributions 
            commencing at different times (for example, multiple annuity starting dates), the limitations must be satisfied as 
            of each annuity starting date, actuarially adjusting for past and future distributions. IRC § 415(b)(1) and (3), 415
This form(d)(1), Regs.is§ 1.415-(a)-1(d)(3)(v),provided1.415(b)-1(b),as1.415(b)-1(c)(5),an example1.415(d)-1.only and should not be 
     609    Section        of the plan must limit the compensation for a year that is used to determine a participant’s 
     completed or returned to the Internal Revenue Service.high three-year average compensation for purposes of § 415 to the amount in effect for that year under § 401(a)
     III.b.
            (17). IRC § 401(a)(17), Regs. § 1.415(b)-1(a)(5)(i), 1.415(c)-2(f).
     610    Section        of the plan must provide that, for purposes of applying the limits of § 415, a retirement benefit 
     III.c. that is payable in any form other than a straight life annuity and that is not subject to § 417(e)(3) must be 
            adjusted to an actuarially equivalent straight life annuity that equals:

Form 6044 (Rev. 4-2016) Catalog Number 43038M  publish.no.irs.gov        Department of the Treasury - Internal Revenue Service

Page 2                                                               CYCLE A Submission Period – 02/01/2016 – 01/31/2017
              (i) for limitation years beginning on or after July 1, 2007, the greater of the annual amount of the straight life 
              annuity (if any) payable under the plan at the same annuity starting date, and the annual amount of a straight 
              life annuity commencing at the same annuity starting date that has the same actuarial present value as the 
              participant’s form of benefit computed using an interest rate of 5 percent and the applicable mortality table under 
              § 417(e)(3).
              (ii) for limitation years beginning before July 1, 2007, the annual amount of a straight life annuity commencing at 
              the same annuity starting date that has the same actuarial present value as the participant’s form of benefit 
              computed using whichever of the following produces the greater annual amount: (1) the interest rate and 
              mortality table or other tabular factor specified in the plan for adjusting benefits in the same form; and (2) a 5 
              percent interest rate assumption and the applicable mortality table.
              The applicable mortality table is the mortality table within the meaning of § 417(e)(3)(B), which is based on 
              mortality table under § 430((h)(3)(A). IRC § 415(b)(2)(B), 415(b)(2)(E), 417(e)(3), and 430(h)(3);  Regs. § 1.415
              (b)-1(a), (b) and (c), 1.417(e)-1(d), Rev. Rul. 98-1, 1998-1 C.B. 249, Rev. Rul. 2001-62, 2001-2 C.B. 632.
       611    Section      of the plan must provide that, for purposes of applying the limits of § 415, a retirement benefit 
       III.d. that is payable in any form other than a straight life annuity and that is subject to § 417(e)(3) must be adjusted to 
              an actuarially equivalent straight life annuity that equals:
              (i) if the annuity starting date is in a plan year beginning after 2005, the annual amount of the straight life annuity 
              commencing at the same annuity starting date that has the same actuarial present value as the participant’s 
              form of benefit, using whichever of the following produces the greatest annual amount: (1) the interest rate and 
              the mortality table or other tabular factor specified in the plan for adjusting benefits in the same form; (2) a 5.5 
              percent interest rate assumption and the applicable mortality table; and (3) the applicable interest rate under § 
              417(e)(3) and the applicable mortality table, divided by 1.05.
              (ii) if the annuity starting date is in a plan year beginning in 2004 or 2005, the annual amount of the straight life 
              annuity commencing at the same annuity starting date that has the same actuarial present value as the 
              participant’s form of benefit payable, using whichever of the following produces the greater annual amount: (1) 
              the interest rate and mortality table or other tabular factor specified in the plan for adjusting benefits in the same 
              form; and (2) 5.5 percent interest and the applicable mortality table.
              (iii) if the annuity starting date is on or after the first day of the first plan year beginning in 2004 and before 
              December 31, 2004, and the plan applies the transition rule in § 101(d)(3) of PFEA ’04 in lieu of the rule in (ii), 
              the annual amount of the straight life annuity commencing at the same annuity starting date that has the same 
              actuarial present value as the participant’s form of benefit, determined in accordance with Notice 2004-78.
              The applicable mortality table is the mortality table within the meaning of §417(e)(3)(B), which is based on 
              mortality table under § 430((h)(3)(A). IRC § 415(b)(2)(B), 415(b)(2)(E) and 417(e)(3), and 430(h)(3); Regs. § 
              1.415(b)-1(a), (b) and (c), 1.417(e)-1(d); Rev. Rul. 98-1, 1998-1 C.B. 249; Rev. Rul. 2001-62, 2001-2 C.B. 632; 
              Notice 2004-78, 2004-2 C.B. 879.
       612    Section     of the plan must provide that where a retirement benefit is provided beginning before age 62, 
       III.e. the benefit will be limited to:
              (i) if the annuity starting date is in a limitation year beginning before July 1, 2007, the annual amount of a benefit 
              payable in the form of a straight life annuity commencing at the participant’s annuity starting date that is the 
              actuarial equivalent of the dollar limitation under § 415(b)(1)(A) (as adjusted under § 415(d)), with actuarial 
              equivalence computed using whichever of the following produces the smaller annual amount: (1) the interest 
              rate and mortality table or other tabular factor specified in the plan for determining actuarial equivalence for 
              early retirement purposes; or (2) a 5 percent interest rate assumption and the applicable mortality table.
              (ii) if the annuity starting date is in a limitation year beginning on or after July 1, 2007, and the plan does not 
              have an immediately commencing straight life annuity payable at both age 62 and the age of benefit 
              commencement, the annual amount of a benefit payable in the form of a straight life annuity commencing at the 
              participant’s annuity starting date that is the actuarial equivalent of the dollar limitation under § 415(b)(1)(A) (as 
              adjusted under § 415(d)), with actuarial equivalence computed using a 5 percent interest rate assumption and 
              the applicable mortality table and expressing the participant’s age based on completed calendar months as of 
              the annuity starting date.
              (iii) if the annuity starting date is in a limitation year beginning on or after July 1, 2007, and the plan has an 
This formimmediatelyiscommencingprovidedstraight life annuity payableasatanboth ageexample62 and the age of benefit commencement,only and should not be 
              the lesser of (1) the adjusted dollar limitation determined in accordance with (ii); and (2) the product of the dollar 
       completed or returned to the Internal Revenue Service.limitation under § 415(b)(1)(A) (as adjusted under § 415(d)) multiplied by the ratio of the annual amount of the 
              immediately commencing straight life annuity under the plan at the participant’s annuity starting date to the 
              annual amount of the immediately commencing straight life annuity under the plan at age 62, both determined 
              without applying the limitations of § 415. 
              The applicable mortality table is the mortality table within the meaning of § 417(e)(3)(B), which is based on 
              mortality table under § 430((h)(3)(A). IRC § 415(b)(2)(C) and 415(b)(2)(E)(i) and (v); Regs. § 1.415(b)-1(d); Rev. 
              Rul. 2001-62, 2001-2 C.B. 632. 
Form 6044 (Rev. 4-2016) Catalog Number 43038M publish.no.irs.gov              Department of the Treasury - Internal Revenue Service

Page 3                                                                     CYCLE A Submission Period – 02/01/2016 – 01/31/2017
       613    If the benefit under the plan commences after age 65, the plan may provide that dollar limitation under § 415(b)
       III.f. (1)(A)(as adjusted under § 415(d)) on such benefit is increased to: 

              (i) if the annuity starting date is in a limitation year beginning before July 1, 2007, the annual amount of a benefit 
              payable in the form of a straight life annuity commencing at the participant’s annuity starting date that is the 
              actuarial equivalent of the dollar limitation under § 415(b)(1)(A)(as adjusted under §415(d)), with actuarial 
              equivalence computed using whichever of the following produces the smaller annual amount:  (1) the interest 
              rate and mortality table or other tabular factor specified in the plan for determining actuarial equivalence for 
              delayed retirement purposes; or (2) a 5 percent interest rate assumption and the applicable mortality table. 

              (ii) if the annuity starting date is in a limitation year beginning on or after July 1, 2007, and the plan does not 
              have an immediately commencing straight life annuity payable at both age 65 and the age of benefit 
              commencement, the annual amount of a benefit payable in the form of a straight life annuity commencing at the 
              participant’s annuity starting date that is the actuarial equivalent of the dollar limitation under § 415(b)(1)(A)(as 
              adjusted under § 415(d)), with actuarial equivalence computed using a 5 percent interest rate assumption and 
              the applicable mortality table and expressing the participant’s age based on completed calendar months as of 
              the annuity starting date. 

              (iii) if the annuity starting date is in a limitation year beginning on or after July 1, 2007, and the plan has an 
              immediately commencing straight life annuity payable at both age 65 and the age of benefit commencement, 
              the lesser of (1) the adjusted dollar limitation determined in accordance with (ii); and (2) the product of the dollar 
              limitation under § 415(b)(1)(A)(as adjusted under §415(d)) multiplied by the ratio of the annual amount of the 
              immediately commencing straight life annuity under the plan at the participant’s annuity starting date to the 
              annual amount of the immediately commencing straight life annuity under the plan at age 65, both determined 
              without applying the limitations of §415. 

              The applicable mortality table is the mortality table within the meaning of § 417(e)(3)(B), which is based on 
              mortality table under § 430((h)(3)(A). IRC § 415(b)(2)(D) and 415(b)(2)(E)(iii); Regs. § 1.415(b)-1(e);  Final 
              Regulations under § 430(h)(3), 73 FR 44632,  Rev. Rul. 2001-62, 2001-2 C.B. 632.
       614    Because the plan’s Normal Retirement Age (NRA) is less than 65, the plan must coordinate the requirements 
       III.g. for actuarial increase for delayed retirement and nonforfeitability of benefits with the limits of § 415 so that post-
              NRA actuarial increases do not cause the benefit to exceed those limits. One way to satisfy these requirements 
              is to suspend the participant’s benefit as permitted under § 411(a)(3)(B). However, the prohibition on amending 
              a plan to place greater restrictions or conditions on § 411(d)(6) protected benefits by adding or modifying a 
              suspension of benefits provision may eliminate suspension as an option. In this case, the plan must provide for 
              the in-service payment of the participant’s benefit if the participant has reached NRA and the benefit cannot be 
              actuarially increased without violating § 415. IRC § 411(a)(3); Regs. §1.411(d)-3(a)(3), 1.411(d)-3(j)(3); Rev. 
              Rul. 2001-51, 2001-2 C.B. 427, Q&A-4.
       615    The plan may provide that the otherwise applicable limitations on benefits of § 415(b) of the Code do not apply 
       III.h. where the total employer-derived retirement benefits payable to a participant under this defined benefit plan and 
              all other qualified defined benefit plans of the employer do not exceed $10,000 in the aggregate. Where a plan 
              provides the $10,000 minimum benefit limitation, the plan must provide that the minimum benefit limitation is not 
              applicable for a participant whose employer maintains or has maintained a defined contribution plan in which 
              such employee participated. In the case of a multiemployer plan, the $10,000 minimum benefit limitation applies 
              regardless of whether the participant ever participated in another plan of the employer, provided that no such 
              other plan was maintained as a result of collective bargaining with the same employee representative as the 
              multiemployer plan. IRC § 415(b)(4) and Regs. § 1.415(b)-1(f).
       616    Section              of the plan must provide that the percentage of compensation limitation of § 415(b)(1)(B) and 
       III.i. the $10,000 minimum benefit limitation of § 415(b)(4), if provided, must be reduced where a participant has less 
              than 10 years of service with the employer at the time the participant begins to receive retirement benefits under 
              the plan. The reduction is made by multiplying the applicable limitation by the following fraction: Years of service 
              with the employer as of, and including, the current limitation year, divided by 10. IRC § 415(b)(5)(B), Regs. § 
              1.415(b)-1(g)(2).
       617    Section              of the plan must provide that the dollar limitation of § 415(b)(1)(A) (as adjusted under 
ThisIII.j.    form§ 415(d)) mustisbeprovidedreduced where a participantashas lessanthan 10 yearsexampleof participation when retirementonlybenefitsand should not be 
              under the plan commence.  The reduction is made by multiplying the dollar limitation by the following fraction: 
       completed or returned to the Internal Revenue Service.Years of participation with the employer as of, and including, the current limitation year, divided by 10. IRC § 
              415(b)(5)(A), Regs. § 1.415(b)-1(g)(1).

Form 6044 (Rev. 4-2016) Catalog Number 43038M       publish.no.irs.gov                Department of the Treasury - Internal Revenue Service

Page 4                                                           CYCLE A Submission Period – 02/01/2016 – 01/31/2017
       618    Except as provided in the following paragraph with respect to multiemployer plans (as defined in § 414(f)), 
       III.k. section    of the plan must provide that all defined benefit plans of the employer (or a predecessor 
              employer), whether or not terminated, will be treated as one defined benefit plan for purposes of the limitations 
              under IRC § 415(b). (For this purpose, if the employer maintains a plan that provides a benefit which the 
              participant accrued while performing services for a former employer, the former employer is a predecessor 
              employer with respect to the participant in the plan.  A former entity that antedates the employer is also a 
              predecessor employer with respect to a participant if, under the facts and circumstances, the employer 
              constitutes a continuation of all or a portion of the trade or business of the former entity.)  Each of the defined 
              benefit plans must contain provisions which limit each so that the possibility is precluded that the aggregate 
              defined benefit plan may exceed the limitations of § 415(b). Where the employer is a member of a controlled 
              group of corporations or commonly controlled trades or businesses, or a member of an affiliated service group 
              within the meaning of sections 414(b), (c) or (m) and 415(g) and (h), the plan must provide that all such 
              employers are treated as a single employer for purposes of the plan's application of the § 415 limitations. See § 
              1.415(f)-1for rules regarding the benefits required to be taken into account when plans are aggregated. 

              Multiemployer plans are not aggregated with other multiemployer plans for purposes of § 415. In addition, if the 
              employer maintains a multiemployer plan and that plan so provides, only the benefits under the multiemployer 
              plan that are provided by the employer are treated as benefits provided under the employer’s plans that are not 
              multiemployer plans.  Finally, a multiemployer plan is disregarded for purposes of applying the percentage of 
              compensation limitation under § 415(b)(1)(B) to a plan which is not a multiemployer plan. IRC § 415(f)(1)(A) and 
              414(m)(4), and Regs. § 1.415-8(a)(1) and 1.401(a)-1(b)(1)(iii).
       619    Section    of the plan should be amended to provide that the plan's definition of compensation for § 415 
       I.c.   purposes includes remuneration for fishing-rights related income, for years beginning after November 15, 2013. 
              Prop. Reg. § 1.415(c)–2(g)(9)

This form is provided as an example only and should not be 

       completed or returned to the Internal Revenue Service.

Form 6044 (Rev. 4-2016) Catalog Number 43038M publish.no.irs.gov             Department of the Treasury - Internal Revenue Service

                                                                              CYCLE A Submission Period – 02/01/2016 – 01/31/2017
                                               Employee Benefit Plan 

                       Limitation on Contribution and Benefits 
                                    (Worksheet Number 6 – Determination of Qualification)
Instructions – All items must be completed unless the contrary is specifically provided. A "Yes" answer indicates a favorable 
conclusion is warranted while a "No" answer indicates a problem exists. Please use the space on the worksheet to explain any "No" 
answer. Numbers in brackets refer to EDS paragraph numbers. See Publication 7001, Explanation Number 6, for guidance in 
completing this form.
The technical principles in this worksheet may be changed by future regulations or guidelines.
Name of plan

I. General Definitions                                                                          Plan Reference        Yes No                            N/A
     a. If the plan defines the limitation year that will be used for purposes of IRC § 415, 
     does the definition meet the requirements of the regulations? [0601]
     b. Does the plan's definition of compensation satisfy the requirements of IRC § 415(c)
     (3) and the regulations? [0602]
     c. If the plan is sponsored by an Indian tribal government, does the plan's definition of 
     compensation for § 415 purposes include remuneration for fishing-rights related 
     income, for years beginning after November 15, 2013, as required by regulations 
     under IRC § 415? [0619]
II. Limitations On Contributions–Defined Contribution Plans and Certain Defined 
                                                                                                Plan Reference        Yes No                            N/A
     Benefit Plans 
Note: If the plan is a defined benefit plan, complete this Part II only if the plan provides for employee contributions or employer contributions to an 
individual medical benefit account. 
     a. If the plan includes a definition of annual additions, does the definition satisfy the 
     requirements of the Code and regulations? [0603]
     b. Are annual additions on behalf of any participant during the limitation year limited to 
     the lesser of (i) 100% of the participant's compensation or (ii) $40,000 adjusted for 
     cost-of-living increases pursuant to § 415(d)? [0604]
     c. If the plan provides a mechanism by which excess annual additions due to (i) a 
     reasonable estimation of a participant's annual compensation, or (ii) a reasonable 
     error in determining the amount of elective deferrals under § 402(g)(3), or (iii) an 
     allocation of forfeitures are reduced, does the mechanism conform to one of the 
     methods described in the 1981 regulations and does the plan limit the application of 
     the mechanism to limitation years beginning before July 1, 2007? [0605]
     d. If the plan provides for contributions on behalf of participants who have become 
     permanently and totally disabled, as defined in § 22(e)(3), does the plan provide for 
     the continuation of contributions on behalf of all such disabled participants for a 
     fixed or determinable period or only  for non-highly compensated employees who 
     become disabled, and are contributions nonforfeitable when made? [0606]
     e. If the employer maintains another qualified defined contribution plan (or a defined 
     benefit plan to which employee contributions are made or under which employer 
     contributions are made to an individual medical benefit account, or a welfare benefit 
     fund under which employer contributions are made to an account of a key employee 
     to provide post-retirement medical benefits), do the provisions of the plan or plans 
     preclude the possibility that the limitations of this Part II will be exceeded when all 
     such plans are treated as one plan? [0607]
III. LimitationsThisonformBenefits–Definedis provided as an examplePlan Reference                                     onlyYes No                        N/Aand should not be Benefit Plans
     a. Is the annual benefit to which any participant is entitled, during the limitation year, 
     completed or returned to the Internal Revenue Service.
     limited to the lesser of (i) 100% of the participant's average compensation for the 
     high three years of service, or (ii) $160,000 (or such larger amount as adjusted for 
     cost-of-living increases pursuant to § 415(d))? [0608]
     b. Does the plan limit the compensation for a year that is used in determining the high 
     three-year average compensation to the amount in effect for that year under § 401
     (a)(17)? [0609]
Form 8384 (Rev. 4-2016)             Catalog Number 62510X  publish.no.irs.gov            Department of the Treasury - Internal Revenue Service

Page 2                                                                                        CYCLE A Submission Period – 02/01/2016 – 01/31/2017
III. Limitations on Benefits–Defined Benefit Plans – Continued                                           Plan Reference             Yes No N/A
c. If the plan provides for a retirement benefit which is payable in a form other than a straight life annuity, and the form of benefit is 
not subject to § 417(e)(3), is the benefit, for purposes of applying the limitation in Ill.a., adjusted to an actuarially equivalent 
straight life annuity that equals:
(i) For limitation years beginning on or after July 1, 2007, the greater of the annual 
       amount of the straight life annuity (if any) payable under the plan at the same 
       annuity starting date, and the annual amount of a straight life annuity 
       commencing at the same annuity starting date that has the same actuarial 
       present value as the participant’s form of benefit computed using an interest rate 
       of 5 percent and the applicable mortality table under § 417(e)(3) and
(ii) For limitation years beginning before July 1, 2007, the annual amount of a 
       straight life annuity commencing at the same annuity starting date that has the 
       same actuarial present value as the participant’s form of benefit computed using 
       whichever of the following produces the greater annual amount: (1) the interest 
       rate and mortality table or other tabular factor specified in the plan for adjusting 
       benefits in the same form; and (2) a 5 percent interest rate assumption and the 
       applicable mortality table? [0610]
d. If the plan provides for a retirement benefit which is payable in a form other than a straight life annuity, and the form of the benefit 
is subject to § 417(e)(3), is the benefit, for purposes of applying the limitation in III.a., adjusted to an actuarially equivalent straight 
life annuity that equals:
(i) If the annuity starting date is in a plan year beginning after December 31, 2005, 
       the annual amount of the straight life annuity commencing at the same annuity 
       starting date that has the same actuarial present value as the participant’s form 
       of benefit, using whichever of the following produces the greatest annual amount: 
       (1) the interest rate and the mortality table or other tabular factor specified in the 
       plan for adjusting benefits in the same form; (2) a 5.5 percent interest rate 
       assumption and the applicable mortality table; and (3) the applicable interest rate 
       under § 417(e)(3) and the applicable mortality table, divided by 1.05;
(ii) If the annuity starting date is in a plan year beginning in 2004 or 2005, the annual 
       amount of the straight life annuity commencing at the same annuity starting date 
       that has the same actuarial present value as the participant’s form of benefit 
       payable, using whichever of the following produces the greater annual amount: 
       (1) the interest rate and mortality table or other tabular factor specified in the plan 
       for adjusting benefits in the same form; and (2) 5.5 percent interest and the 
       applicable mortality table; and
(iii) If the annuity starting date is on or after the first day of the first plan year 
       beginning in 2004 and before December 31, 2004, and the plan applies the 
       transition rule in § 101(d)(3) of PFEA ’04 in lieu of the rule in (ii), the annual 
       amount of the straight life annuity commencing at the same annuity starting date 
       that has the same actuarial present value as the participant’s form of benefit, 
       determined in accordance with Notice 2004-78? [0611]
e. If a plan provides a retirement benefit beginning before age 62, is the benefit limited to:
(i) If the annuity starting date is in a limitation year beginning before July 1, 2007, 
       the annual amount of a benefit payable in the form of a straight life annuity 
       commencing at the participant’s annuity starting date that is the actuarial 
       equivalent of the dollar limitation determined under line III.a., with actuarial 
       equivalence computed using whichever of the following produces the smaller 
       annual amount:  (1) the interest rate and mortality table or other tabular factor 
       specified in the plan for determining actuarial equivalence for early retirement 
       purposes; or (2) a 5 percent interest rate assumption and the applicable mortality 
       table;
This(ii) If the annuityformstarting dateisis in aprovidedlimitation year beginning on orasafter Julyan1, example only and should not be 
       2007, and the plan does not have an immediately commencing straight life 
       annuity payable at both age 62 and the age of benefit commencement, the completed or returned to the Internal Revenue Service.
       annual amount of a benefit payable in the form of a straight life annuity 
       commencing at the participant’s annuity starting date that is the actuarial 
       equivalent of the dollar limitation determined under line III.a., with actuarial 
       equivalence computed using a 5 percent interest rate assumption and the 
       applicable mortality table and expressing the participant’s age based on 
       completed calendar months as of the annuity starting date; and 

Form 8384 (Rev. 4-2016)         Catalog Number 62510X            publish.no.irs.gov                    Department of the Treasury - Internal Revenue Service

Page 3                                                                          CYCLE A Submission Period – 02/01/2016 – 01/31/2017
III. Limitations on Benefits–Defined Benefit Plans – Continued                                     Plan Reference         Yes No N/A
(iii) If the annuity starting date is in a limitation year beginning on or after July 1, 
       2007, and the plan has an immediately commencing straight life annuity payable 
       at both age 62 and the age of benefit commencement, the lesser of (1) the 
       adjusted dollar limitation determined in accordance with (ii); and (2) the product 
       of the dollar limitation under line III.a. multiplied by the ratio of the annual amount 
       of the immediately commencing straight life annuity under the plan at the 
       participant’s annuity starting date to the annual amount of the immediately 
       commencing straight life annuity under the plan at age 62, both determined 
       without applying the limitations of § 415? [0612]
f.  If the retirement benefit under the plan may begin after age 65, does the plan provide for an increase in the maximum dollar 
limitation on benefits that is limited to:
(i) If the annuity starting date is in a limitation year beginning before July 1, 2007, 
       the annual amount of a benefit payable in the form of a straight life annuity 
       commencing at the participant’s annuity starting date that is the actuarial 
       equivalent of the dollar limitation determined under line III.a., with actuarial 
       equivalence computed using whichever of the following produces the smaller 
       annual amount:  (1) the interest rate and mortality table or other tabular factor 
       specified in the plan for determining actuarial equivalence for delayed retirement 
       purposes; or (2) a 5 percent interest rate assumption and the applicable mortality 
       table;
(ii) If the annuity starting date is in a limitation year beginning on or after July 1, 
       2007, and the plan does not have an immediately commencing straight life 
       annuity payable at both age 65 and the age of benefit commencement, the 
       annual amount of a benefit payable in the form of a straight life annuity 
       commencing at the participant’s annuity starting date that is the actuarial 
       equivalent of the dollar limitation determined under line III.a., with actuarial 
       equivalence computed using a 5 percent interest rate assumption and the 
       applicable mortality table and expressing the participant’s age based on 
       completed calendar months as of the annuity starting date; and
(iii) If the annuity starting date is in a limitation year beginning on or after July 1, 
       2007, and the plan has an immediately commencing straight life annuity payable 
       at both age 65 and the age of benefit commencement, the lesser of (1) the 
       adjusted dollar limitation determined in accordance with (ii); and (2) the product 
       of the dollar limitation under line III.a. multiplied by the ratio of the annual amount 
       of the immediately commencing straight life annuity under the plan at the 
       participant’s annuity starting date to the annual amount of the immediately 
       commencing straight life annuity under the plan at age 65, both determined 
       without applying the limitations of § 415? [0613]
g. If the plan’s normal retirement age is less than 65, does the plan coordinate the 
requirements for actuarial increase for delayed retirement and nonforfeitability of 
benefits with the limits of § 415, for example, by providing for the in-service 
distribution of a participant’s benefit where post-NRA actuarial increases would 
cause the benefit to exceed those limits? [0614]
h. If the plan provides a minimum retirement benefit that otherwise exceeds the 
limitations on benefits in Ill.a., is such benefit provided only to a participant whose 
retirement benefits under the plan and all other defined benefit plans of the 
employer do not, in the aggregate, exceed $10,000 for the limitation year? [0615]
i.  If a participant has less than 10 years of service at the time the participant begins to 
receive retirement benefits under the plan, is the percentage of compensation limit 
in Ill.a.(i), as adjusted as described in III.e. or III.f., if applicable, and the minimum 
benefit limit in Ill.h., if applicable, reduced by multiplying those limits by a fraction, 
Thisthe numeratorformof which is theisnumberprovidedof years of service with theasemployeranas of, example only and should not be 
and including, the current limitation year, and the denominator of which is 10? 
[0616]completed or returned to the Internal Revenue Service.
j.  If a participant has less than 10 years of participation at the time the participant 
begins to receive retirement benefits under the plan, is the dollar limit in III.a.(ii), as 
adjusted as described in III.e. or III.f., if applicable, reduced by multiplying the limit 
by a fraction, the numerator of which is the number of years of participation with the 
employer and the denominator of which is 10? [0617]

Form 8384 (Rev. 4-2016)      Catalog Number 62510X      publish.no.irs.gov                   Department of the Treasury - Internal Revenue Service

Page 4                                                           CYCLE A Submission Period – 02/01/2016 – 01/31/2017
III. Limitations on Benefits–Defined Benefit Plans – Continued                            Plan Reference    Yes No N/A
k. If the employer (or a predecessor employer) maintains, or at one time maintained, 
another qualified defined benefit plan, do the provisions of the plan or plans 
preclude the possibility that the limitations of this Part III. will be exceeded when all 
such defined benefit plans are treated as one plan? [0618]

This form is provided as an example only and should not be 

       completed or returned to the Internal Revenue Service.

Form 8384 (Rev. 4-2016) Catalog Number 62510X publish.no.irs.gov               Department of the Treasury - Internal Revenue Service