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Posted

Fiscal Year Plan, 10/1 - 9/30. Plan terminates 9/30/00, assets are distributed 12/15/00. Employer wants to adopt new S/H plan effective 10/1/01. Can we treat this as a "new" plan for safe harbor rules or does the fact that assets from the old plan were not distributed until 12/15/00 make this a "successor" plan.

Any guidance is appreciated.

Posted

I found my own answer. New DC plan shouldn't really be established until after the distributions from the terminated k plan. May work out better anyway, may be able to take advantage of EGTRRA with a short plan beginning 01/01/02.

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