5310 Determination Letter Upon Termination of Cash Balance Plan

[Guest num1]

Prior to imposition of the IRS moratorium on cash balance conversions, a DB Plan obtained a favorable IRS determination on its conversion to a cash balance formula. The plan sponsor now wants to terminate the converted plan. Will the IRS issue a 5310 (termination determination) to this sponsor (assuming that all qualification requirements are met) or will the matter be blocked under the moratorium?

[MGB]

Most likely blocked. Whenever the field reviewers see cash balance in the plan, they are supposed to forward to the national office where it will just sit. However, there is always the small probability that your particular reviewer will not send it to national and process it normally (this has happened).