Comment on Proposed Amendments to Sec. 415 Regulations - Sƒ

COMMENTS OF The THE ERISA INDUSTRY COMMITTEE ERISA Industry PROPOSED AMENDMENTS TO THE REGULATIONS CommitteON THE LIMITATIONS ON BENEFITS AND CONTRIBUTIONS UNDER QUALIFIED PLANS July 27, 2005 1The ERISA Industry Committee ("ERIC") is pleased to submit the following comments on the proposed amendments to the regulations under Internal Revenue Code (“Code”) section 415 regarding the limitations on benefits and contributions under tax-qualified plans. The proposed regulations were published in the May 31, 2005, issue of the Federal Register. 70 Fed. Reg. 31,214. The preamble to the proposed regulations states that comments on the proposed regulations must be submitted by July 27, 2005. ERIC reserves the right to supplement these comments to reflect any additional concerns that its members identify as a result of their continued attention to the proposed regulations. I. Background Section 415 limits the benefits that a qualified defined benefit plan may provide to a participant and the additions that may be made to a participant’s account in a year under a qualified defined contribution plan. Every tax-qualified plan is subject to the § 415 limits. 1 ERIC is a nonprofit association committed to the advancement of the employee retirement, health, incentive, and compensation plans of America's major employers. ERIC’s members provide comprehensive benefits to tens of millions of active and ...