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IRS: Transfer of At Least 25% of DB Plan's Surplus Assets to DC Plan Avoids Income Tax
Internal Revenue Service [IRS] 
[Official Guidance] July 1, 2003
Revenue Ruling 2003-85. Excerpt: [T]he direct transfer from Plan A to Plan B of $20X, an amount that is at least 25 percent of the maximum amount which the employer could receive as an employer reversion, is treated as follows: the amount transferred is not includible in the gross income of the employer, no deduction is allowable with respect to the amount transferred, and the amount transferred is not treated as an employer reversion for purposes of § 4980.
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