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Missing Participant Distribution Redux--Practitioner Preference?


Guest Katharine Jungkind
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Guest Katharine Jungkind

What is the prevailing approach for distributions when a DC plan is terminated with favorable determination letter, all searches, IRS & SSA letter forwarding requests completed without the participant being found? I'd like some feedback from practitioners on whether the preferred approach is to use the forfeiture approach approved by the regulations (although the regs appear to specify that the participants be 65) or to try the 100% withholding option? Does the approach vary depending on whether the account balance is greater or less than $5,000?

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What about the IRA rollover option in this Revenue Ruling?

http://www.benefitslink.com/IRS/revrul2000-36.shtml

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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