PTE for an In-Kind Contribution to a DB Plan

[Guest CRC02]

A client is interested in applying for a prohibited transaction exemption to make an in-kind contribution to its DB. In-kind contributions are definitely prohibited transactions--a 1995 Intepretive Bulletin made that very clear. Has anyone ever made a successful application for PTE for in-kind contributions, or run across someone else's successful application? I found one PTE for GM for an in-kind contribution, but that case involved some pretty hefty cash contributions ($4B) in addition to the in-kind contribution, and the proposed transaction was the result of PBGC/GM negotiations. Any thoughts?

[Guest b2kates]

short answer, not recently.

you do not state what type of property.

Why not contribute cash and have plan purchase?