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Did you look at IRS Notice 98-4, Q& A E-1?

Co. A acquires Co. B in an asset acquisition in November 2015. Co. B sponsored a plan, but the plan was terminated at acquisition. Some participants did roll their balances into Co. A, but rollovers didn't actually occur until January and February of 2016. Bob was 72 at the time of the acquisition, but still employed. He terminates in July 2016. A couple of RMD issues: 1. It is my understanding that there would not be a 2016 rmd for Bob. He did not have a balance in Co. A's plan at 12/31/15. 2. Should have Co. B's plan issued an rmd for 2015? My understanding is yes because the employer changed at Co. B's acquisition. Thanks in advance for any guidance.

1.410(b)-7(d) If an employer treats two or more separate plans as a single plan under this paragraph, the plans MUST be treated as a single plan for all purposes under sections 401(a)(4) and 410(b) ............ in other words, if you combined them coverage you have no choice but to combine them for the ADP test. if you don't combine them for coverage then you can't combine them for ADP testing. and yes, it could happen that someone who might normally not get a refund if tested separately gets a refund if you have to combine.

Or inaction, as the case may be!

Side note: if it's a small company, did losing the CPS and a few of the staff create a partial plan term?