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Text of IRS Revenue Ruling 2008-40: Transfers from Tax-qualified Plan to Nonqualified Foreign Trust or Puerto Rican Plan (PDF)
Internal Revenue Service [IRS] 
[Official Guidance] July 1, 2008
9 pages. Certain transition relief is provided; also discusses application of section 410(b) minimum coverage rules to employees in Puerto Rico and other possessions of the United States. Excerpt: HOLDINGS: 1. A transfer of amounts from a trust under a plan qualified under § 401(a) to a nonqualified foreign trust is treated as a distribution from the transferor plan. 2. A transfer of assets and liabilities from a qualified plan to a plan that satisfies section 1165 of the Puerto Rico Code is also treated as a distribution from the transferor plan, even if the plan is described in section 1022(i)(1) of ERISA.
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