Change in Asset Method

[abanky]

Here's the background...

for all of history and 2008, the plan used MVA

2009 and 2010, the plan used 2 year smoothing

Can I get automatic approval to change the AVA to MVA for 2011? or do I have to get approval?

Andrew

[david rigby]

IMHO, you need approval. The logic works like this:

1. If you read reg. 1.430(g)-1©(i), approval needed.

2. If you read Rev. Proc. 2000-40, sec. 3.10, approval not needed.

3. But the IRS has stated this about RP 2000-40:

Gray Book Q&A 2010-13

PPA: Funding: Change in Funding Method

Rev. Proc. 2000-40 provides for automatic approval of certain changes in funding method. May multiemployer plans and plans with a delayed effective date for PPA funding rules still rely on such approvals?

RESPONSE

Yes.

The above Response is a summary, prepared by representatives of the Program Committee, of the oral responses to the question posed to certain staff members of the Treasury and IRS, which represent only personal views of the individuals who provided them. Accordingly, the Response does not necessarily represent the positions of the Treasury or the IRS and cannot be relied upon by any taxpayer for any purpose.