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The 2025 Advantage: How CPAs Can Leverage Retroactive Cash Balance Plans

The end of 2025 is upon us, and while we all work diligently to wrap things up ahead of the new year, some retirement plan opportunities aren’t ready to wrap up just yet. One such opportunity is the adoption of cash balance plans, which can provide powerful retirement and tax-planning opportunities. Thanks to recent legislative changes, cash balance plans may be adopted retroactively, which means CPAs can assist clients in securing significant tax deductions for 2025, even after the close of the plan year. For professional service businesses, closely held businesses, and other employers, retroactive cash balance plans can be transformative.

Why Retroactive Adoption Matters: Businesses can now establish cash balance plans up to the extended deadline for their tax returns and still treat the plan as adopted as of the last day of the prior taxable year. This allows 2025 contributions to a cash balance plan to be funded well into 2026, providing increased flexibility and a larger window of time for tax planning. Further, compared to defined contribution retirement plans, such as 401(k) plans, cash balance plans typically allow for larger contribution limits that generally increase with age, often allowing business owners to lower their taxable income by significant amounts.

Who Can Benefit: Although any business can establish a cash balance plan, such plans are often especially beneficial for high-earning business owners who want to reduce taxable income, such as professional service employers (e.g., law firms, engineering firms, and medical practices), and closely held corporations. It is important to remember, however, that once established, cash balance plans generally require annual contributions, even in difficult economic times. Accordingly, cash balance plans are best suited to businesses with reliable cash flow.

Key Considerations: To determine whether a retroactive cash balance plan is appropriate, CPAs should explore the following:

1. Income Level and Tax Exposure

  • Does your client generally have high taxable income?
  • Would a large, deductible contribution meaningfully reduce their tax burden?
  • Does your client also qualify for the retirement plan start-up tax credit available under SECURE 2.0? (Be sure to read January’s article for more information on these credits)
2. Cash Flow
  • Can the business reliably make required annual contributions over the long term?
3. Existing Retirement Plan Usage
  • Is the business already maximizing a 401(k) or profit-sharing plan? (This is not required, but it might indicate the business could benefit from additional tax deferral opportunities.)
4. Timing and Tax Filings
  • Does the client plan to extend their 2025 tax return to maximize time for plan design and funding?
  • What deadlines must be met to ensure retroactive adoption is compliant?
5. PBGC Coverage and Exemptions
  • Cash balance plans are required to pay annual premiums to a governmental agency called the PBGC that insures defined-benefit pension benefits, unless an exemption applies.
  • Many cash balance plans of smaller employers are exempt from premium payments under exemptions for small professional service employer plans and substantial owner plans.
  • Businesses can request a coverage determination from the PBGC to know whether they are required to pay PBGC premiums and comply with other applicable PBGC rules.
Takeaways: Retroactive adoption of cash balance plans is a powerful tax planning tool for business owners aiming to reduce taxable income while accelerating retirement savings. CPAs play a crucial role in identifying potential candidates for this type of plan and coordinating with plan administrators. As you consider whether a cash balance plan may be beneficial for your clients, be sure to work with your actuary partners to model projected coverage and benefit requirements, likely contributions to the plan, and anticipated tax deductions. As year-end planning continues, carefully considering the needs of your clients and the benefits of a cash balance plan can help clients take advantage of opportunities that might otherwise be overlooked.
 
Jesse St. Cyr, Partner, Poyner Spruill
Jesse is a member of the Employee Benefits and Executive Compensation team at Poyner Spruill LLP. He represents clients before the IRS and DOL in matters involving employee benefits. Jesse has experience working with a diverse range of benefits and compensation matters and has extensive experience working with a variety of employers. Jesse is recognized by Chambers USA as a leading lawyer for Business (Employee Benefits & Executive Compensation).

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ERISA Workplace Retirement Plan Limits

The federal government annually publishes updated qualified retirement plan limits, which impact the contributions, benefit accruals, and compliance of ERISA covered qualified retirement plans. The below tables summarize the most significant changes in recent history.


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