PBGC premium required when spinoff occurs

[Guest meggie]

I believe this is true- but looking for confirmation.

Plan B spins off of Plan A effective 2/1/2002 (assets and liabilities). Plan A is a calendar plan year and Plan B will have a short plan year from 2/1/02 through 12/31/2002 and 1/1 thereafter.

The spin off is not de-minimus.

I believe that both plans have to pay 2002 premiums. Plan A based on census as of 12/31/01. Plan B as a new plan and based on 2/1/2002 census. Hence, there are unavoidable overlapping premiums for 2002 and proration is not available.

Any comments??