david rigby

Caution: this is an actuarial assumption. Do not assume the valuation count equals the PBGC participant count.

Don't want to put words in Andy's mouth, but I think his use of "contractural" was a reference to plan provisions. That is, does the Plan require the purchase of an annuity?

IMHO, a definition that refers to 417e means you must use all 3 segment rates. This is a recipe for confusion and error. I suggest amending the plan to make sure only one rate (maybe the pre-PPA rate) is used.

Can you help by providing a source?

Funding Standard CarryOver Balance If all assets were distributed under a termination, does not that define the end of the final plan year? and the plan no longer exists?

Maybe, but that is (probably) a different question. I've wondered the same thing as the original question, which I restate in my own words: "When a NQ payment is being made to an employee/retiree and the payment is subject to FICA, does the FICA (and FUTA?) taxation change if a portion or survivor benefit is paid to a beneficiary?"

If it were me, I might want to be talking to my attorney before making such suggestion.

Andy, your answer is better than mine. My apologies for thinking the original question was silly. (Perhaps the original questioner should have described his/her relationship to the plan/sponsor/actuary). Possibly, the sponsor asked the actuary to help with something (not having any idea the consequences) and the actuary responded (correctly) that it could be accomplished only by changing the plan year. The result is the actuary is seen as "requesting" a change.

Well, duh! Changing the plan year can only be accomplished via plan amendment. Does the actuary have such authority?

The instructions say "The plan administrator must sign...", and "the employer must sign...". No doubt, DOL regs provide more description of the former, perhaps about the latter. Does Ima's boss care if Ima signs the form? (I suspect your fact set is pretty common.)

Why? Does the plan define the ER contribution as discretionary?

IMHO, the PPA language is clear that your burn as much CB to get the plan to a needed threshold level, but don't burn anything if you can't get there. For example, see IRC 436(f)(3).

Probably, it's mostly a survey of job satisfaction, with factors for compensation, lack of heavy lifting, etc. Don't know if there are any factors for "future prospects".

Ask the "broker" to produce evidence supporting the position? You provide similar evidence (i.e., plan provisions), and see if the broker can justify his/her position.

Discussion here about IRS and SSA letter forwarding programs. http://benefitslink.com/boards/index.php?showtopic=40445

Don't know if it's current, but PA did not.

Don't know if your situation is "sham" or simply "remarry". Some discussion here.

You are correct. It affects the VRP only.

Could it be less, under PPA section 405?

I would never sell my copy. Priceless.

I haven't parsed the language, but there could be an inconsistency without an amendment. (Note that "inconsistency" is not the same as "wrong".) For example, PPA06 included language that requires plan modification in certain circumstances (such as the automatic freeze if a funding level drops below a certain level). Somewhere in the future, every plan must be amended to incorporate that concept, but we don't know yet how to do it. Thus, your plan may have that deficiency. However, it is difficult to see how a terminated one-person plan could suffer any harm by not having the language. In 2010, when the IRS provides some guidance (ha ha), it seems unlikely they will require modification for plans that no longer exist. But, what do I know. Discuss with your ERISA attorney?

What is a "WRERA amendment"? Covers what provisions?

I'm aware of waiver in the case of termination of a PBGC-covered plan, the intent being to make a plan fully funded in a standard termination. Is there another scenario?

Since WRERA changed PPA06 back to the latter's orginal effective date, it would seem that any 2008 plan year is affected. What particular section of WRERA is your focus?

I love RPN. Once you get used to it, nothing else measures up. However, with the 17BII, you can choose RPN or "conventional". Another advantage to the 17B is that it will accept non-integral "n" in a time value of money calculation.