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JimA writes:

It would appear that in a defined benefit plan you are a participant if you are eligible,even if you opt out. However, for a money-purchase plan, a contribution is necessary to be considered a participant. I think the accountant is just misreading this section.

You are correct, and the accountant is not. A defined contribution plan is NOT a defined benefit plan. In the latter, if you are eligible, then you are a participant because the employer contributes on your behalf to fund an ultimate pension benefit. In a defined contribution plan like a money purchase or profit sharing, if neither you nor your employer contributes, then you are NOT a participant even when you are eligible to participate but elect not to do so.

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