Can In-Kind PT Contributions be reflected on MFSA?

[Guest billkalke]

Since hearing an IRS actuary say so at an EA meet a few years ago I've thought that it was not permissable to include on a DB plan's minimum funding standard account in-kind contributions (which in general would be a prohibited transaction).

However, I'm having trouble finding written guidance to this effect and would appreciate it if anyone can point me toward some.

[david rigby]

If an in-kind contribution is not permitted (except perhaps via PTE), then logically it follows that it cannot be included in the funding standard account. Have I misunderstood your question?

BTW, you may find some discussion in prior threads, via the Search feature.

[Guest billkalke]

As I understand it, making an in-kind contribution to a retirement plan to satisfy a funding requirement results in a prohibited transaction with excise tax consequences and a requirement to something be done to fix the problem. However, fixing the problme and paying the excise tax will often (usuallly?) not be done before the final minimum funding date for the plan year.

Thus the ea for the plan must decide whether or not to include the in-kind contribution on the minimum funding standard account. My question is whether any one knows of written guidance as to whether or not it is permissable to include the contribution on the MFSA.

BNA, I believe, in their analysis on in-kind contributions states that in general they are deductible, but their comment didn't to me seem to address the issue of inclusion by the ea on the MFSA.