Calavera

Agree with LANDO. There are 2 separate CGs: X & Y, and C & D.

Most likely he will be 100% vested in company's B benefit upon merger even if he took a distribution from company A.

http://www.asppa.org/News/Browse-Topics/Details/ArticleID/5554/DOL-Initiative-on-Missing-Plan-Audit-Reports

But a predecessor plan is the one that terminated.

This is what I thought too. 1.411(a)-5 talks about vesting service. However, unless I am missing something, I don't see that you have to make 100% vesting just because empoyer has another qualified plan. Additionally under 1.401(a)(9)-6 A -1© - All benefit accruals as of the last day of the first distribution calendar year must be included in the calculation of the amount of annuity payments for payment intervals ending on or after the employee's required beginning date. In your case the first distribution year is 2014 but 12/31/2014 accrued benefit is $0. I also suggest to set NRD as 65 + 3 years of participation and no early retirement benefits.

Where does it say that vesting has to be 100% because she has another qualified plan?

Same in DB. So, pay the proper amount to participant before end of this year. Then: Option 1: VCP - cost $500 + preparation fees - excize tax relief is a part of the filing Option 2: Advise to file Form 5329 together with tax forms including "tear-stained" letter explaining the situation and ask for forgiveness. See instruction for the Form 5329 https://www.irs.gov/pub/irs-pdf/i5329.pdf

Deja vu ... http://www.nytimes.com/2014/07/13/upshot/this-road-work-made-possible-by-underfunding-pensions.html?_r=0

i) and ii) should use Applicable Mortality (that is what AMT probably stands for) iii) should use plan's mortality So if maturity value of 10.2 correspond to the applicable mortality, 415 lump sum is $1,020,000

It still the same 2 years after the later of an adoption date or an effective date. Step 1: later of adoption date or an effective date (12/31/2008 in SoCal's example) Step 2: add 2 years to the date from Step 1 (12/31/2010) Step 3: Ther will be no cushion adjustment at valuation date after the date from Step 2 (1/1/2011)

Good old Pre-PPA days.

If amendment was adopted 3/15/14, you will not use it for cushion purposes until 1/1/17 valuation. BTW, after the Q/A-4 of the 2011 Gray Book a lot of people wouldn't use the amendment adopted 3/15/14 for 1/1/2013 valuation at all.

I don't think you can exclude the unused vacation pay unless you actually amend the definition of compensation. Additionally note that unused vacation pay paid no later than 2 1/2 months after the termination of employment was subjest of Post-EGTRRA "Good Faith" Amendment somewhere in 2009. At that time election could have been maid to include or exclude it for 415 compensation purposes. Not sure if this helps in any way.

So under separate interest DRO participant started receiving his benefits, and AP allowed to defer. I don't see any issues here. The issue would be: how to calculate AP benefits? 1. What is the latest participant's age AP can defer (NRD or RBD)? 2. How does DRO describe the timing of the split (at NRD or at participant's commencement)? 3. Is AP entitled for ER subsidy? 4. If AP is entitled to a subsidy, do you calculate AP's benefit at participant's commencement and actuarially increase it to AP's commencement? Or do you simply calculate AP's benefits at her commencement applying the same level of subsidy that participant would get at that time?

I don't have an answer. However, when I have any unexplained browsing issues, clearing cash, deleting temporary Internet files, and rebooting PC sometimes helps.

TL calculated for HCEs for cushion purposes will be based on old 80% formula for 1/1/13, 1/1/14, and 1/1/15 valuations.

Yes, notice should be issued to affected participants that they cannot get their lump sum upon termination of employment. However, if there are no vested benefit yet, there are no affected participants.

http://www.actuary.org/files/qualification_standards.pdf http://www.irs.gov/pub/irs-utl/regulations2012.pdf

Crossover age maybe much higher than 68 if you have less than 10 years of participation but more than 10 years of service at those 68+ ages.

It is easier to reach an agreement between owners on the level of contributions, and/or tax deductions under a cash balance defined benefit plan,than under a standard defined benefit plan.

I am ignoring the legality of $100k-in / $100k-out scheme, and only discussing the AFTAP. I am not sure if there are any AFTAP issues from the 436 benefit restrictions perspective. AFTAP for EOY val is (MVA + Contribution)/(TL + NC). So you have MVA=$0, Contribution =$100k, TL=$0 (assumed) and NC for the minimum funding purposes probably below $100K (since $100K satisfies the minimum contribution with interest). This will give you AFTAP over 100%.

Look at the bright side. Sole proprietor hire his spouse, and both of them in the DB/DC plans covered by PBGC with the full DC contribution up to 25% of net income.

Since amendment was timely adopted before 12/31/2014, make election under 412(d)(2) to recognize it as of 1/1/2014. Then change assumptions to immediate retirement and $100k of annual benefits. It should bump your max to the level you need to deduct it all in 2014.

This is easy. Any modifications of the fully generational RP14/MP14 require (per auditors) you to prove that this is the best of the best. Somehow the fully generational RP14/MP14 is the best of the best without any proof needed.

We had several auditors requested using the RP 2014 mortality for 1/1/2014 liability measurement based on the following: http://www.aicpa.org/InterestAreas/FRC/DownloadableDocuments/TQA_Sections/TQA_Section_3700_01.pdf Reason: by the time the information is presented (i.e. time of the Form 5500 filing), the new mortality should be used for the accounting purposes.