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Here is the scenario: A client has a one participant overfunded DB plan, no 2013 contributions needed or made. He wants to terminate effective in 2013 and transfer excess assets to a DC plan escrow account, but the actual transfer won't happen until 2014. The question is, can he release from escrow for 2013 (up to his DC annual addition)? My presumption is yes, since aside from the lack of a deducation, it is little different from an accrued contribution. I would think that the termination resolution should specify the intent to accrue the transfer for 2013
