Non-spouse Beneficiary rollovers

[KJohnson]

1) Particpant dies in 2005

2) Plan provides for life expectancy rule.

3) Non-spouse beneficary takes distribuiton purusant to life expectancy rule in 2006.

Do you agree that the non-spouse beneficiary can rollover the remaining amounts in 2007 (after taking the 2007 life expectancy distribution)? It seems to me that there is no need for any "transition relief" in this case (which based on an article today in BenefitsLink it doesn't appear the IRS is going to provide):

3/14/2007: No Transitional Relief for Rollover to Nonspouse, IRS Official Says (The Bureau of National Affairs, Inc.)

Excerpt: "The Internal Revenue Service made the decision not to provide transitional relief under Section 829 of the Pension Protection Act for years prior to 2006 regarding nonspouse beneficiary rollovers, an Internal Revenue Service official said March 9."

I know the plan will need to be amended to provide for non-spouse rollovers, but what is the amendment deadline. Is it 2009 with other PPA amendments with just operational compliance until then?

[Bird]

I agree that this is ok and doesn't need any special relief.

My understanding at this time is that operational compliance until PPA amendments are required (2009 or whenever) is ok.