Rev. Rul. 2020-2: Covered compensation tables for 2020 plan year

Covered compensation tables for 2020 plan year

The IRS today released an advance version of Rev. Rul. 2020-2 providing tables of covered compensation under section 401(l)(5)(E) for the 2020 plan year.

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Rev. Rul. 2020-2 [PDF 93 KB] provides that for purposes of determining covered compensation for the 2020 year, the taxable wage base is $137,700.

For the 2019 plan year, the taxable wage base was $132,900.

Today’s revenue ruling includes two tables to be used in determining benefits for defined benefit plans that use “permitted disparity” in employer-provided contributions or benefits (as allowed under section 401(l))—

  • An actual table
  • A rounded table that aggregates different years of birth

Background

“Permitted disparity” allows an employer to provide an additional benefit (either contribution or accrual) for employees whose compensation is above a certain limit, which is often the social security wage base. A qualified plan may be integrated with the social security limit to provide a more uniform benefit when taking into account that social security provides a benefit targeted at lower paid employees. “Permitted disparity” limits the differences that can be provided between lower and higher paid employees.

“Covered compensation” for an employee is defined by Reg. section 1.401(l)-1(c)(7) as the average of the taxable wage bases in effect for each calendar year during the 35-year period ending with the last day of the calendar year in which the employee attains social security retirement age. For purposes of determining the amount of an employee's covered compensation, a plan may use IRS-provided tables that are developed by rounding the actual amounts of covered compensation for different years of birth.

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