American Academy of Actuaries Comments on Notice 2007-28

The American Academy of Actuaries released a four-page comment on Notice 2007-28 which they sent to the IRS. It contains a very simple example of how the interpretation of the combined deduction interpretation in Q&A9 will impact a plan. The example walks through what happens to the deduction limit for a sponsoring employer with a defined benefit plan when they implement a defined contribution plan with a one percent contribution. They are requesting the IRS to review the interpretation, or at least to provide relief to sponsoring employers who interpreted the deduction limit for 2006 differently than stated in Notice 2007-28. [tags]Pension Protection Act, Notice 2007-28, deduction, defined benefit, defined contribution, ppa[/tags]