Timing of PPA Amendment

[MarZDoates]

I know that a terminating plan must be updated for all current legislation. However, does the amendment (i.e. PPA) need to be done before the assets are distributed or after? Please provide citation. Thank you.

[Bird]

It seems to me that in order to distribute assets, you have to terminate the plan. And a requirement to terminate the plan is to bring it up to date...I was going to say there's no cite but I'm guessing the latest rev proc on amending plans says something like the deadline for amending for PPA is the earlier of plan termination or [whatever the remedial amendment date is].

Having said that, if you submit for a determination letter you'll have a chance to fix any omissions even if assets have been distributed.