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requirements that a trust must meet in order to constitute a
"qualified trust," and sets forth certain restrictions that
preclude qualification of a trust. Section 401(a)(16) sets forth
the restriction in issue in the instant case. Section 401(a)(16)
provides:
A trust shall not constitute a qualified trust under
this section if the plan of which such trust is a part
provides for benefits or contributions which exceed
the limitations of section 415.
Section 415(a)(1) provides that a trust which is part of a
pension, profit-sharing, or stock bonus plan shall not constitute
a qualified trust under section 401(a) if--
(B) in the case of a defined contribution plan,
contributions and other additions under the plan
with respect to any participant for any taxable
year exceed the limitation of subsection (c) * * *
Section 415(c)(1) provides:
(1) In general.--Contributions and other additions with
respect to a participant exceed the limitation of this
subsection if, when expressed as an annual addition (within
the meaning of paragraph (2)) to the participant's account,
such annual addition is greater than the lesser of--
(A) $30,000,[3] or
(B) 25 percent of the participant's compensation.
3Sec. 415(c)(1)(A) was amended by the Tax Reform Act of 1986
(TRA 1986), Pub. L. 99-514, sec. 1106(a), 1106(i), 100 Stat.
2420, 2425, effective for years beginning after Dec. 31, 1986, to
read $30,000 (or, if greater, 1/4 of the dollar limitation
[$90,000] in effect under subsection (b)(1)(A))". It was further
amended to eliminate the parenthetical language effective for
years commencing after Dec. 31, 1994. See Uruguay Round
Agreements Act, Pub. L. 103-465, sec. 732(b)(2), 108 Stat. 5005
(1994).
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