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refers to the deduction of contributions "In the taxable year
when paid". However, section 404(a)(1)(A) does not specify the
method by which the actual amount of the deduction may be
determined.
The applicable limitations on contributions to CBA Plans in
this case are contained in clauses (i) and (iii) of section
404(a)(1)(A), which together provide that the overall limitation
is the greater of the amount necessary to satisfy the minimum
funding standard of section 412(a) for plan years ending within
the employer's taxable year, and an amount equal to the normal
cost of the plan, augmented by any amount necessary to amortize
unfunded costs equally over 10 years. In addition, the flush
language at the end of subparagraph (A) of the foregoing section
provides, among other things, that the maximum amount deductible
for the taxable year is to equal the full funding limitation for
such year determined under section 412.
As a further refinement of the section 404(a) limitations on
the deductibility of contributions, section 413 provides certain
rules that apply exclusively to "Collectively bargained plans,
etc." Section 413(a) provides that subsection (b) applies to any
plan (and any trust thereunder) maintained pursuant to a CBA;
i.e., a CBA Plan. Various paragraphs of subsection (b) provide
rules that relate to CBA Plans, but the relevant paragraph for
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