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Legal Alert: IRS Announces 2012 Cost-of-Living Increases to Pension Plan Limits

Date   Oct 20, 2011

On October 20, 2011, the Internal Revenue Service announced cost of living adjustments affecting various limitations applicable to pension and other retirement plans (IR 2011-103).

 

On October 20, 2011, the Internal Revenue Service announced cost of living adjustments affecting various limitations applicable to pension and other retirement plans (IR 2011-103). Many of the limitations remain unchanged because they are indexed in $1000 or $5000 increments, but several will change for 2012. Some of the better-known limitations are:

  • The limitation on elective deferrals (salary reduction contributions) under 401k, 403(b), and most 457(b) plans, as well as the federal government's Thrift Savings Plan, is increased from $16,500 to $17,000.
  • The limit on "catch-up contributions" for those who are age 50 and over remains unchanged at $5,500.
  • The limit on compensation that may be taken into account under a plan is $250,000, up from $245,000.
  • The overall limitation on "annual additions" to a participant's account under a defined contribution plan is increased from $49,000 to $50,000.
  • The basic limitation on the annual benefits under a defined benefit plan is increased from $195,000 to $200,000.
  • The dollar threshold for determining who is a "highly compensated employee" is increased to $115,000, from $110,000.
  • The limitations applicable to SIMPLE and SEP plans (other than the $250,000 compensation limitation) are unchanged.
  • The phase-out of deductions for IRA contributions will occur between $58,000 and $68,000 of AGI (previously $56-66,000) for single individuals and unmarried heads of household who are covered by an employer's retirement plan; for married couples filing joint returns, the phase-out occurs between $92,000 and $112,000 of AGI (previously $90-110,000) where the contributing spouse is covered by an employer's plan, or between $173,000 and $183,000 (previously $169-179,000) where only the noncontributing spouse is covered by an employer's plan.
  • The phase-out for taxpayers making contributions to a Roth IRA is from $173,000 to $183,000 (previously $169-179,000) for married couples filing jointly, and from $110,000 to $125,000 (previously $107-122,000) for unmarried individuals. (For married individuals filing a separate return and who are covered by an employer's retirement plan, the phase-out range remains at $0 to $10,000.)
  • The dollar threshold for determining which officers are "key employees" in a top heavy plan is increased from $160,000 to $165,000.
  • The Social Security Taxable Wage Base increases to $110,100 from $106,800.

A complete list of the indexed limitations, as well as a history of the changes since 1989, can be found at http://www.irs.gov/pub/irs-tege/cola_table.pdf.

If you have any questions regarding the new limitations, please feel free to contact the author of this Legal Alert, Jeffrey Ashendorf, jashendorf@fordharrison.com, any member of Ford & Harrison's Employee Benefits Practice Group or the Ford & Harrison attorney with whom you usually work.