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Pro-Rate Shortfall on Short Plan Year DB Plan


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-DB Plan is frozen

-Short Plan Year from 10/1/18 through 12/31/18

-Plan has a shortfall of $100,000

Question - For the purposes of minimum funding, do you pro-rate the shortfall amortization charge for 12/31/118?

Please provide source/link/site.  Thank-you

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Short plan years were discussed in the proposed reg published in the Federal Register 04/15/08.  Also included in the final reg published in the Federal Register 09/09/15.  The latter can also be found in Internal Revenue Bulletin 2015-39, found here:  https://www.irs.gov/irb/2015-39_IRB.  Did your research agree with this?

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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