In
Notice 2015-28, the IRS extended the temporary
nondiscrimination relief originally provided in Notice 2014-5 for
certain "closed" defined benefit pension plans.
Closed defined benefit pension plans are defined benefit plans
that provide ongoing accruals but have been amended to limit those
accruals to some or all of the employees who participated in the
plan on a specified date. The employees to whom the defined benefit
plan is closed are often generally covered by a defined
contribution plan maintained by the employer.
In many cases, the defined benefit plan covers more highly
compensated employees than the defined contribution plan does,
making it difficult or impossible for the defined benefit plan to
satisfy coverage and nondiscrimination requirements. However, the
defined benefit plan can often comply with the requirements if the
defined benefit and defined contribution plans are tested together
as if they were one defined benefit plan, with the
