rcline46 Posted February 4, 2016 Report Share Posted February 4, 2016 I remember that after PPA, the plan termination date was to be treated as a plan year end and certain items had to be pro-rated (compensation, deferrals and such). Now I cannot find ANYTHING that backs up my memory! Not only that, I am being challenged by an attorney. HELP!!!! Thanks all. Link to comment Share on other sites More sharing options...
Belgarath Posted February 4, 2016 Report Share Posted February 4, 2016 Try 1.415(j)-1(d)(3). Link to comment Share on other sites More sharing options...
rcline46 Posted February 4, 2016 Author Report Share Posted February 4, 2016 Thank you! Link to comment Share on other sites More sharing options...
Tom Poje Posted February 4, 2016 Report Share Posted February 4, 2016 with a caveatat the 2010 ASPPA Conference Q and A 3, in regards to a terminated plan and top heavy the IRS person indicated the following:(1) Of course, if there is no employer contribution, there would not be an obligation to provide topheavy minimum contribution. But, if there were contributions to keys during the year, includingelective deferrals, there is a top heavy minimum based on compensation and employmentthrough 9/15/10. Plan must liquidate within a reasonable time under Rev. Rul. 89-87 or else9/15 date may not be reasonable. There is effectively a short plan year for top heavy purposes. in other words, if the assets aren't paid out then you could lose the 'short plan year' Link to comment Share on other sites More sharing options...
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