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david rigby

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Everything posted by david rigby

  1. http://www.irs.gov/pub/irs-drop/n-09-92.pdf
  2. 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
  3. Extension in IRS Notice 2009-97, released today.
  4. 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.
  5. And an actuary who is familiar with FAS 87/158.
  6. Need more info about what you mean by "convert".
  7. Why not just take the (periodic) distribution?
  8. Pardon my confusion. What does it mean that you "have a DB plan" that has been taken over by the PBGC?
  9. 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 ......"
  10. What does the plan say?
  11. 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.
  12. 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.
  13. Just an opinion: the intent of the exemption is to cover a plan with a hard freeze, not any variation of a soft freeze.
  14. Depends on the plan document itself.
  15. 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.
  16. Putting transferred in quotes may or may not be significant. Perhaps you can provide some more details?
  17. If you search the regs (which you can find here: http://www.irs.gov/retirement/content/0,,id=96685,00.html), using a key word "short", there is only one brief paragraph that applies.
  18. I've done this, just as AtA suggests. Most retirees will elect the annuity. In hindsight, the communication of this option was very difficult, not well understood, and not worth the bother.
  19. Data as of 30-NOV-09 (Monday) Moody's Daily Long-term Corporate Bond Yield Averages Utilities Industrial Corporate Aaa NA 5.01 5.01 Aa 5.25 5.14 5.20 A 5.54 5.51 5.53 Baa 6.04 6.35 6.20 Avg 5.61 5.50 5.56 Moody's Daily Treasury Yield Averages Short-Term (3-5 yrs) 0.56 Medium-Term (5-10 yrs) 2.09 Long-Term (10+ yrs) 3.72
  20. Made me look. It seems my answer was hasty. I think Sieve is correct. (I saw nothing on point in the regs, or in the Gray Book.) Some earlier discussions: http://benefitslink.com/boards/index.php?showtopic=43303 http://benefitslink.com/boards/index.php?showtopic=14055
  21. Notwithstanding your punctuation, or lack thereof: If the EE is vested 100% at termination, then vested 100% at rehire.
  22. Because the Feds can make up any accounting rules they choose.
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