Transfer to foreign affiliate

[Guest carsca]

Is anyone aware of an IRC cite or other authority which would allow a 401(k) plan to make a distribution to an employee who transfers employment within a controlled group to a foreign affiliate (i.e., a related company outside the US)?

I understand that such a transfer is not technically a separation from service or a severance from employment, but I have seen plan documents which state that if an employee remains employed with the foreign affiliate for a period of time after the transfer (say, five years) under certain circumstances a distribution is permitted, but I can't verify this.

Thanks in advance.