bito'money

Hi B, 

you had some follow up questions related to the Puerto Rico plan Termination. Please find my finding. 

Is the plan with a cash or deferred arrangement? Does it have a match or after tax feature, or just profit sharing?

Is the plan PR-qualified only or dual-qualified in both US and PR?  

Is it 401k or 1081.01(e) plan, can you confirm that the plan sponsor does not sponsor an alternative defined contribution plan that would subject the distributions to the successor plan rule under both the US and PR law?

• Its a Deferred arrangement and it does have a Match 
• its Dual- Qualified but only 11 participants with balance and all are in PR 
• its a 401K and plan sponsor does have other 401k plans however I don't believe there is any restriction on distribution.

Could you share your thoughts how the Termination can be handled and also is there any guidelines on Puerto Rico plan termination that might help.