david rigby

Reviewing two documents for the same plan. 1. Original document states that under $5K lump sums will be distributed within 90 days after end of plan year of termination of employment. 2. Proposed document states that under $5K lump sums will be distributed after a break-in-service. Does 2 fail 411(d)(6)?

Andy is correct. See IRS Notice 2008-85. http://www.irs.gov/retirement/article/0,,id=96699,00.html

Married. Used to it.

Let's see if this link works: http://thomas.loc.gov/cgi-bin/query/z?c111:H.R.4126: The current language of HR4126 indicates that target plans would not get any special treatment, so they would suffer the same fate as any cross-tested DC plan. However, cash balance plans do get special treatment. Just as interesting is the proposed change to 410(b). As one with actuarial letters after my name, I believe (of course) that everyone should have a DB plan, and all actuaries should be fully employed. But, neither the Congress nor the IRS has asked for my opinion.

It may be hasty to assume that any money given to any government will be used to enhance the lives of anyone.

Boom! Well done, Mike.

See Interest Rates on this page: http://www.pbgc.gov/practitioners/index.html

Disagree. Professional courtesy. There may also be issues w/r/t outstanding invoices and/or service agreement.

http://www.irs.gov/pub/irs-drop/n-09-92.pdf

http://www.irs.gov/pub/irs-drop/n-09-97.pdf You can subscribe to IRS GuideWire here: http://www.irs.gov/newsroom/content/0,,id=154810,00.html

Extension in IRS Notice 2009-97, released today.

Never once encountered an auditor who cared about the FAS35 assumptions. Since PVAB (fas35) and ABO (fas87) and funding target (IRS) are essentially the same concept, there should be value in having them be the same (or similar). But not required. They have different purposes, so don't overlook the documentation of the assumptions. FAS35 has been around a long time (1980), well before the concept of ABO and funding target, and well before any financial statement recognition. It is much less important now.

And an actuary who is familiar with FAS 87/158.

Need more info about what you mean by "convert".

Why not just take the (periodic) distribution?

Pardon my confusion. What does it mean that you "have a DB plan" that has been taken over by the PBGC?

Sieve could be correct. However, refer to the Plan B language where it references Company A. Does that language have any conditions on it? Such as, "service with A prior to xx/yy/zz will be recognized in B if ......"

What does the plan say?

Might be 50%, but not necessarily. Could be 20%. See IRC 4980(d)(1) and (d)(3). Is this a one-person plan (or possibly owner plus spouse)? If so, then no discrimination issues, just 415 limits.

Losses? Can't be determined yet (other than the percent in IRC 4980). There may not be any excess, especially if the plan is amended to increase the benefit to "use up" the excess.

Just an opinion: the intent of the exemption is to cover a plan with a hard freeze, not any variation of a soft freeze.

Search for DOMA.

Depends on the plan document itself.

I called the DOL to ask about reporting a REIT. Response: "It would not be incorrect to show it on Line 1c(6) of Scheudle H. However, if you are uncomfortable showing it there, it can be reported on Line 1c(15)." (Don't you just love double negatives?) Use this "advice" however you wish.

Putting transferred in quotes may or may not be significant. Perhaps you can provide some more details?