Part-time employees revisited

[Guest kjungkin]

While virtually all of 401(a) does not apply to plans of state & local governmental employers due to TRA '97, what is the status of the requirement that benefits be definitely determinable? This is imposed under Regs 1.401-1(B)(i) and appears to still be applicable to governmental plans (ref Carol Calhoun's article on DROP plans). All of the old rev rulings on in-service distributions and distributions made to participants when transferred to different job locations (thus becoming ineligible to participate) do not qualify under 401(a) rely on this provision in the regs (60-281, 60-323, 74-254, etc.) Does this impose a limitation on governmental employers to treat employees going from full-time to part-time as terminated, and allowing distribution of benefits?