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IRS Announces Inflation-Adjusted Dollar Limits for 2004

Client Alert | 1 min read | 12.22.03

In IR-2003-122, the IRS announced the limitations applicable to contributions and benefits under various employee benefit provisions of the Code for 2004, as adjusted for changes in the cost of living. The 2004 limits are as follows:

Item
2004
2003
Maximum annual annuity payable from a tax-qualified defined benefit pension plan at age 65
$165,000
$160,000
Maximum "annual addition" to a participant's account under a tax-qualified defined contribution plan
$41,000
$40,000
Elective Deferrals under Code Section 402(g)
$13,000
$12,000
SIMPLE plan elective contributions
$9,000
$8,000
(2003)
Section 401(a)(17) Limit on annual amount of a participant's compensation that can be taken into account for contribution or benefit purposes under a tax-qualified retirement plan
$205,000
$200,000
Section 401(a)(17) compensation limit with COLA adjustment
$305,000
$300,000
Compensation threshold for definition of "highly compensated employee"
$90,000
$90,000
Compensation limit for determining "key employees" for top-heavy plan purposes
$130,000
$130,000
Compensation limit for definition of "control employee for fringe benefit valuation purposes
$80,000
$80,000
Compensation limit for definition of "control employee for fringe benefit valuation purposes
$80,000
$80,000
ESOP five-year distribution limit
$830,000
$810,000

 

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Client Alert | 3 min read | 11.21.25

A Sign of What’s to Come? Court Dismisses FCA Retaliation Complaint Based on Alleged Discriminatory Use of Federal Funding

On November 7, 2025, in Thornton v. National Academy of Sciences, No. 25-cv-2155, 2025 WL 3123732 (D.D.C. Nov. 7, 2025), the District Court for the District of Columbia dismissed a False Claims Act (FCA) retaliation complaint on the basis that the plaintiff’s allegations that he was fired after blowing the whistle on purported illegally discriminatory use of federal funding was not sufficient to support his FCA claim. This case appears to be one of the first filed, and subsequently dismissed, following Deputy Attorney General Todd Blanche’s announcement of the creation of the Civil Rights Fraud Initiative on May 19, 2025, which “strongly encourages” private individuals to file lawsuits under the FCA relating to purportedly discriminatory and illegal use of federal funding for diversity, equity, and inclusion (DEI) initiatives in violation of Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (Jan. 21, 2025). In this case, the court dismissed the FCA retaliation claim and rejected the argument that an organization could violate the FCA merely by “engaging in discriminatory conduct while conducting a federally funded study.” The analysis in Thornton could be a sign of how forthcoming arguments of retaliation based on reporting allegedly fraudulent DEI activity will be analyzed in the future....

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