Andy the Actuary Posted September 27, 2012 Share Posted September 27, 2012 FYI In the IRS phone forum on MAP-21, today, Michael Spaid, IRS Actuary posed a question from a forum participant, "Assume a DB plan implements MAP-21 effective 2012 as intended by the law. If the Plan prescribes that the 110% test to determine restrictions on pre-termination distributions to HCEs under 401(a)(4) uses Funding Target as a proxy for Current Liability, then for this purpose may the FT recognize the MAP-21 rates?" Mr. Spaid commented, "The IRS is not taking a position on this. Do what seems reasonable." The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice. Link to comment Share on other sites More sharing options...
KimberlyC Posted January 9, 2013 Share Posted January 9, 2013 Thank you. So he didn't say it was reasonable, but didn't say it was totally off. Does anyone have clients who are using the rates for this purpose? Link to comment Share on other sites More sharing options...
Andy the Actuary Posted January 9, 2013 Author Share Posted January 9, 2013 Yes, I, all of them. The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice. Link to comment Share on other sites More sharing options...
Guest Jeff Hartmann Posted January 10, 2013 Share Posted January 10, 2013 In my opinion, it is quite "reasonable" to use MAP-21 interest rates for the 110% test, since those rates are being used for AFTAP's. All of our 110% calcs use MAP-21 rates. Link to comment Share on other sites More sharing options...
SoCalActuary Posted January 10, 2013 Share Posted January 10, 2013 I agree. We are not required to have 110% of the lump sum liquidation value before paying an HCE. Link to comment Share on other sites More sharing options...
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