2020 Annual Benefit Plan Limits

Akin Gump Strauss Hauer & Feld LLP

The Internal Revenue Service (IRS) on November 6, 2019 announced the following cost of living inflation adjusted dollar limits applicable to tax-qualified plans and other benefit plans for 2020:

Retirement Plan Limits

  • 401(k) Elective Deferrals - The limit on the maximum amount of elective contributions that a person may make to a Section 401(k) plan, a Section 403(b) tax-sheltered annuity or a Section 457(b) eligible deferred compensation plan is increased from $19,000 to $19,500.
  • Catch-up Contributions - The limit on “catch-up contributions” to a Section 401(k) plan, a Section 403(b) tax-sheltered annuity or a Section 457(b) eligible deferred compensation plan for persons age 50 and older is increased from $6,000 to $6,500.
  • Defined Contribution Limit - The dollar limit on the maximum permissible allocation under a defined contribution plan is increased from $56,000 to $57,000.
  • Defined Benefit Limit - The maximum annual benefit under a defined benefit plan is increased from $225,000 to $230,000. The limit applicable to participants who separated from service before January 1, 2020 is the participant’s compensation limitation, as adjusted through 2019, multiplied by 1.0176.
  • Compensation Limit - The maximum amount of annual compensation that may be taken into account on behalf of any participant under a qualified plan will increase from $280,000 to $285,000.
  • Highly Compensated Employees (HCE) Limit - The dollar amount used to identify “highly compensated employees” is increased from $125,000 to $130,000.
  • Employee Stock Ownership Plan (ESOP) Distribution Timing - The dollar amount under Section 409(o)(1)(C)(ii) for determining the maximum account balance in an employee stock ownership plan subject to a five year distribution period is increased from $1,130,000 to $1,150,000. The dollar amount used to determine the lengthening of the five year distribution period is increased from $225,000 to $230,000.
  • Key Employee - The dollar amount under § 416(i)(1)(A)(i) concerning the definition of “key employee” in a top-heavy plan is increased from $180,000 to $185,000

Other Benefit Limits

  • Flexible Spending Account (FSA) Limit - For the taxable years beginning in 2020, the cafeteria plan dollar limitation under Section 125(i) on voluntary employee salary reductions for contributions to health flexible spending arrangements is increased from $2,700 to $2,750.
  • Health Savings Account (HSA) Limits - For calendar year 2020, the annual limitation on deductions to a health savings account under Section 223(b)(2)(A) for an individual with self-only coverage under a high deductible health plan is increased from $3,500 to $3,550. For calendar year 2020, the annual limitation on deductions to a health savings account under Section 223(b)(2)(B) for an individual with family coverage under a high deductible health plan is increased from $7,000 to $7,100. The additional catch-up contribution for individuals age 55 and over remains unchanged at $1,000.
  • High Deductible Health Plan - For calendar year 2020, a “high deductible health plan” is defined under § 223(c)(2)(A) as a health plan with an annual deductible that is not less than $1,400 for self-only coverage or $2,800 for family coverage, and the annual out-of-pocket expenses (deductibles, co-payments and other amounts, but not premiums) do not exceed $6,900 for self-only coverage or $13,800 for family coverage.
  • Social Security Wage Base – For calendar year 2020, the social security wage base will be $137,700, which is an increase of $4,800 from $132,900 in 2019.
  • Qualified Transportation - For calendar year 2020, the monthly limitation for the qualified transportation fringe benefit and for qualified parking increased from $260 to $270. The employer deduction for qualified transportation fringe benefits was repealed beginning in 2018.

Additional information regarding retirement plan dollar limits can be obtained in IRS Notice 2019-59. The health savings account limits and the high deductible health plan limits are in Revenue Procedure 2019-25. The FSA and qualified transportation limits are in Revenue Procedure 2019-44. The social security wage base was announced in SSA, Press Release, 10-10-19. A summary chart is attached.

2020 ANNUAL BENEFIT PLAN LIMITS

2019 2020

Defined Contribution

$56,000

$57,000

401(k) Deferrals

$19,000

$19,500

Catch-Up Limit

$6,000

$6,500

Defined Benefit Limit

$225,000

$230,000

Maximum Compensation

$280,000

$285,000

Highly Compensated Employee

$125,000

$130,000

ESOP Distribution Period

$1,130,000

$1,150,000

Additional Increments

$225,000

$230,000

Top Heavy Key Employees

$180,000

$185,000

cafeteria plan health flexible spending arrangements

$2,700

$2,750

HSA Contributions

Self-only coverage

$3,500

$3,550

Family coverage

$7,000

$7,100

HSA catch-up contributions (age 55 or older)

$1,000

$1,000

High Deductible Health Plan

Self-only coverage

Minimum Deductible

$1,350

$1,400

Maximum Out-of-Pocket

$6,750

$6,900

Family coverage

Minimum Deductible

$2,700

$2,800

Maximum Out-of-Pocket

$13,500

$13,800

Social Security Wage Base

$132,900

$137,700

Qualified Transportation or Parking

$260

$270

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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