Qualified Replacement Plan, overfunded DB plan

[John Feldt ERPA CPC QPA]

We have a client that has a small amount of excess (over the 415 limit) in their 3 person DB plan - about $30,000 extra (all employees are at the 415 limit). They are a corporation - for profit (not a tax-exempt employer). They are still a functioning company and will have enough wages to support the allocation in the QRP.

So, if they transfer 100% of the excess assets to a qualified replacement plan, according to 2003-85 it looks like they pay no excise tax, since no reversion occurred (and also avoid income taxes of course). Is this how you would read this?

Is Revenue Ruling 2003-85 still the most current guidance for this?

[Blinky the 3-eyed Fish]

Yes.

Yes, as far as I know.

[John Feldt ERPA CPC QPA]

Thanks!