Q. If an employee over age 50 has two jobs with two SIMPLE-IRA plans, does the aggregate limit on elective deferrals for 2011 apply to the employee? L.K.M., Myrtle Point, Ore.
A. Yes. The limit on deferrals to a SIMPLE-IRA plan in 2011 is $11,500, plus a $2,500 catch-up contribution is allowed for someone age 50 or older. But the aggregate limit for elective deferrals under IRC Section 402(g) is $16,500 and the aggregate catch-up contribution limit is $5,500. (IRS Notice 2009-66)
Thus it seems that an employee with two jobs and two plans would be subject to the aggregate limits of $16,500 and $5,000, respectively.