Partial Termination and Multiple Employer Plan

[Guest CRC02]

Does anyone know how the IRS evaluates whether a partial termination has occurred for an employer who is one of several sponsors of a multiple employer plan?

My guess is that the IRS would look only at the individual employer's employees to determine the appropriate percentages used to evaluate if there has been a partial termination. I'm basing this on the fact it seems more in tune with the spirit of the nondiscrimination rules, and that employers in multiple employer settings are evaluated individually for the purposes of coverage nondiscrimination. However, I haven't been able to find any authority supporting this view. Anyone have an opinion/citation?

[Guest asire2002]

I looked at this and found that in a multiple employer plan context, partial termination is based on the population of the plan as a whole, not on individual employers. I didn't save a cite, but I would start with the 411 regs and also look at the multiple employer plan audit exam guidelines.

[Mike Preston]

I always get them confused unless I look them up, but I think you might be dealing with one of the types of partial termination to the exclusion of the other. I'm referring to the horizontal and vertical partial terminations.