n-17-64.pdf

us-irs-notices-n-17-64n-17-64.pdfGuidance

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2018 Limitations Adjusted As Provided in Section 415(d), etc.

Notice 2017-64
Section 415 of the Internal Revenue Code (the Code) provides for dollar limitations on
benefits and contributions under qualified retirement plans. Section 415(d) requires that the
Secretary of the Treasury annually adjust these limits for cost-of-living increases. Other
limitations applicable to deferred compensation plans are also affected by these adjustments
under § 415. Under § 415(d), the adjustments are to be made under adjustment procedures
similar to those used to adjust benefit amounts under § 215(i)(2)(A) of the Social Security Act.
Cost-of-Living Adjusted Limits for 2018
Effective January 1, 2018, the limitation on the annual benefit under a defined benefit
plan under § 415(b)(1)(A) is increased from $215,000 to $220,000.
For a participant who separated from service before January 1, 2018, the participant’s
limitation under a defined benefit plan under § 415(b)(1)(B) is computed by multiplying the
participant’s compensation limitation, as adjusted through 2017, by 1.0197.
The limitation for defined contribution plans under § 415(c)(1)(A) is increased in 2018
from $54,000 to $55,000.
The Code provides that various other dollar amounts are to be adjusted at the same time
and in the same manner as the dollar limitation of § 415(b)(1)(A). After taking into account the
applicable rounding rules, the amounts for 2018 are as follows:

The limitation under § 402(g)(1) on the exclusion for elective deferrals described in
§ 402(g)(3) is increased from $18,000 to $18,500.
The annual compensation limit under §§ 401(a)(17), 404(l), 408(k)(3)(C), and
408(k)(6)(D)(ii) is increased from $270,000 to $275,000.
The dollar limitation under § 416(i)(1)(A)(i) concerning the definition of “key employee” in a
top-heavy plan remains unchanged at $175,000.
The dollar amount under § 409(o)(1)(C)(ii) for determining the maximum account balance
in an employee stock ownership plan subject to a 5-year distribution period is increased
from $1,080,000 to $1,105,000, while the dollar amount used to determine the lengthening
of the 5-year distribution period is increased from $215,000 to $220,000.
The limitation used in the definition of “highly compensated employee” under
§ 414(q)(1)(B) remains unchanged at $120,000.
The dollar limitation under § 414(v)(2)(B)(i) for catch-up contributions to an applicable
employer plan other than a plan described in § 401(k)(11) or § 408(p) for individuals aged
50 or over remains unchanged at $6,000. The dollar limitation under § 414(v)(2)(B)(ii) for
catch-up contributions to an applicable employer plan described in § 401(k)(11) or 408(p)
for individuals aged 50 or over remains unchanged at $3,000.

The annual compensation limitation under § 401(a)(17) for eligible participants in certain
governmental plans that, under the plan as in effect on July 1, 1993, allowed cost-of-living
adjustments to the compensation limitation under the plan under § 401(a)(17) to be taken
into account, is increased from $400,000 to $405,000.
The compensation amount under § 408(k)(2)(C) regarding simplified employee pensions
(SEPs) remains unchanged at $600.
The limitation under § 408(p)(2)(E) regarding SIMPLE retirement accounts remains
unchanged at $12,500.
The limitation on deferrals under § 457(e)(15) concerning deferred compensation plans of
state and local governments and tax-exempt organizations is increased from $18,000 to
$18,500.
The limitation under § 664(g)(7) concerning the qualified gratuitous transfer of qualified
employer securities to an employee stock ownership plan is increased from $45,000 to
$50,000.
The compensation amounts under § 1.61-21(f)(5)(i) of the Income Tax Regulations
concerning the definition of “control employee” for fringe benefit valuation purposes is
increased from $105,000 to $110,000. The compensation amount under § 1.61-21(f)(5)(iii)
is increased from $215,000 to $220,000.
The dollar limitation on premiums paid with respect to a qualifying longevity annuity
contract under § 1.401(a)(9)-6, A-17(b)(2)(i) of the Income Tax Regulations is increased
from $125,000 to $130,000.
The Code provides that the $1,000,000,000 threshold used to determine whether a
multiemployer plan is a systemically important plan under § 432(e)(9)(H)(v)(III)(aa) is adjusted
using the cost-of-living adjustment provided under § 432(e)(9)(H)(v)(III)(bb). After taking the
applicable rounding rule into account, the threshold used to determine whether a multiemployer
plan is a systemically important plan under § 432(e)(9)(H)(v)(III)(aa) is increased from
$1,012,000,000 to $1,087,000,000.
The Code also provides that several retirement-related amounts are to be adjusted using
the cost-of-living adjustment under § 1(f)(3). After taking the applicable rounding rules into
account, the amounts for 2018 are as follows:
The adjusted gross income limitation under § 25B(b)(1)(A) for determining the retirement
savings contributions credit for married taxpayers filing a joint return is increased from
$37,000 to $38,000; the limitation under § 25B(b)(1)(B) is increased from $40,000 to
$41,000; and the limitation under §§ 25B(b)(1)(C) and 25B(b)(1)(D) is increased from
$62,000 to $63,000.
The adjusted gross income limitation under § 25B(b)(1)(A) for determining the retirement
savings contributions credit for taxpayers filing as head of household is increased from
$27,750 to $28,500; the limitation under § 25B(b)(1)(B) is increased from $30,000 to
$30,750; and the limitation under §§ 25B(b)(1)(C) and 25B(b)(1)(D) is increased from
$46,500 to $47,250.

The adjusted gross income limitation under § 25B(b)(1)(A) for determining the retirement
savings contributions credit for all other taxpayers is increased from $18,500 to $19,000;
the limitation under § 25B(b)(1)(B) is increased from $20,000 to $20,500; and the
limitation under §§ 25B(b)(1)(C) and 25B(b)(1)(D) is increased from $31,000 to $31,500.
The deductible amount under § 219(b)(5)(A) for an individual making qualified retirement
contributions remains unchanged at $5,500.
The applicable dollar amount under § 219(g)(3)(B)(i) for determining the deductible
amount of an IRA contribution for taxpayers who are active participants filing a joint return
or as a qualifying widow(er) is increased from $99,000 to $101,000. The applicable dollar
amount under § 219(g)(3)(B)(ii) for all other taxpayers who are active participants (other
than married taxpayers filing separate returns) is increased from $62,000 to $63,000. If
an individual or the individual’s spouse is an active participant, the applicable dollar
amount under § 219(g)(3)(B)(iii) for a married individual filing a separate return is not
subject to an annual cost-of-living adjustment and remains $0. The applicable dollar
amount under § 219(g)(7)(A) for a taxpayer who is not an active participant but whose
spouse is an active participant is increased from $186,000 to $189,000.
Accordingly, under § 219(g)(2)(A), the deduction for taxpayers making contributions to a
traditional IRA is phased out for single individuals and heads of household who are active
participants in a qualified plan (or another retirement plan specified in § 219(g)(5)) and
have adjusted gross incomes (as defined in § 219(g)(3)(A)) between $63,000 and
$73,000, increased from between $62,000 and $72,000. For married couples filing jointly,
if the spouse who makes the IRA contribution is an active participant, the income phase-
out range is between $101,000 and $121,000, increased from between $99,000 and
$119,000. For an IRA contributor who is not an active participant and is married to
someone who is an active participant, the deduction is phased out if the couple’s income
is between $189,000 and $199,000, increased from between $186,000 and $196,000.
For a married individual filing a separate return who is an active participant, the phase-out
range is not subject to an annual cost-of-living adjustment and remains $0 to $10,000.
The adjusted gross income limitation under § 408A(c)(3)(B)(ii)(I) for determining the
maximum Roth IRA contribution for married taxpayers filing a joint return or for taxpayers
filing as a qualifying widow(er) is increased from $186,000 to $189,000. The adjusted
gross income limitation under § 408A(c)(3)(B)(ii)(II) for all other taxpayers (other than
married taxpayers filing separate returns) is increased from $118,000 to $120,000. The
applicable dollar amount under § 408A(c)(3)(B)(ii)(III) for a married individual filing a
separate return is not subject to an annual cost-of-living adjustment and remains $0.
Accordingly, under § 408A(c)(3)(A), the adjusted gross income phase-out range for
taxpayers making contributions to a Roth IRA is $189,000 to $199,000 for married
couples filing jointly, increased from $186,000 to $196,000. For singles and heads of
household, the income phase-out range is $120,000 to $135,000, increased from
$118,000 to $133,000. For a married individual filing a separate return, the phase-out
range is not subject to an annual cost-of-living adjustment and remains $0 to $10,000.

Drafting Information
The principal author of this notice is Tom Morgan of the Office of the Associate Chief
Counsel (Tax Exempt and Government Entities). However, other personnel from the IRS
participated in the development of this guidance. For further information regarding this notice,
contact Mr. Morgan at 202-317-6700 or John Heil at 443-853-5519 (not toll-free calls).

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