Effective Date of Spun-Off Plan

[Guest jhinkle]

I have generally assumed that the effective date for a spun-off plan should reflect the date that plan assets were spun-off and transferred from the existing plan to the spun-off plan. Could (or should) a spun-off plan ever use the existing plan's original effective date as its own effective date? Seems that could raise potential concerns about why no Form 5500s were ever filed by the spun-off plan in earlier years and other reporting and tax issues; however, for various reasons the plan sponsor here prefers to have the spun-off plan's effective date reflect the original effective date of the existing plan if at all possible. Thanks.