A few Qualified Replacement Plan questions, relating to administering

[John A]

A few Qualified Replacement Plan questions:

1) It is clear that the initial transfer of the DB surplus to a DC plan that is a Qualified Replacement Plan is not deductible. If the surplus is allocated ratably over 7 years as matching and/or profit sharing contributions, it would seem to me that it would not become deductible in the year allocated, correct?

2) Since the amount must be allocated ratably over 7 years, am I correct that the amount to allocate in the 2nd year is:

(the initial amount plus all earnings minus the amount allocated in the first year) divided by 6 (absent any 415 limitations or other considerations)?

3) From a prior thread (answer from PAX), I take it that the surplus is allocated to all participants at the time of the ratable allocation from the suspense account, even if the participant never participated in the DB plan, correct?

4) For anyone that has worked with a DC plan that was a Qualified Replacement Plan and specified allocating the surplus ratably over 7 years, would you have any advice of things to be careful of, or issues that arose that you did not expect?

Thanks for any help.