Andy the Actuary Posted August 14, 2014 Report Share Posted August 14, 2014 I submitted a question for an IRS Webnar on Plan Terminations on whether the IRS position was "exactly" 25% or "at least 25%" of the reversion being transferred to a DC. IRS Rev. Rule 2003-85 indicated that 100% of a DB Plan reversion could get transferred to a DC Plan and no excise tax would apply. I.e., the requirement to transfer exactly 25% was relaxed. It this position consistent with current policy, and if not, where has current policy been codified? The IRS Field Actuary Larry Haberle actually read my question verbatim and then proceeded to indicate that the facts of my question were incorrect. Namely, IRS Rev. Ruling 2003-85 indicated that more than 25% (but not 100%) of the reversion was transferred to a DC plan. That was his response -- not even that the position was, or no longer was, the current IRS thinking. The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice. Link to comment Share on other sites More sharing options...
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