Rollover From Plan with Qualification Failure

[Randy Watson]

Many rollovers were made from a plan that was later found to have a qualification failure. These rollovers were not eligible rollover distributions since the plan did not meet the qualification requirements at the time of the rollovers. Assume the failure is corrected under EPCRS. I'd like to be able to point to some authority that states that IRAs will maintain their favorable tax treatment with the retroactive correction of the plan. I know it makes complete sense that a retroactive correction will cure any rollover issues with the IRA, I'd just like be able to point to something. Please help.