Andy the Actuary Posted March 27, 2008 Posted March 27, 2008 For 2007, Plan reported on Schedule B current liability of $150,000 and excluded preparticipation liability of $100,000. Actuarial value of assets for 2007 was $150,000. Assume no credit balance. Is 2007 AFTAP = 100% or is 2007 AFTAP = 60% [150/250] ? The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.
SoCalActuary Posted March 27, 2008 Posted March 27, 2008 I did not see any reference to the part of cl that is ignored within the new aftap regs. So my vote is 60%
Andy the Actuary Posted March 28, 2008 Author Posted March 28, 2008 So, while there is no reference to 412(l)(7)(D) in the proposed reg., the question remains whether 412(l)(7)(D) is implicit in the calculation of CL? Simply another vague and uncertain provision of that disconbobulation that is affectionately referred to as the PPA. Any other voters out there? The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.
flosfur Posted March 28, 2008 Posted March 28, 2008 I did not see any reference to the part of cl that is ignored within the new aftap regs. So my vote is 60% But by definition, Section 412(l)(7) CL can be determined by disregarding certain % of pre-participation service and the proposed regs do not say, S412(l)(7) CL without regard to S412(l)(7)(D). So my vote be for 100%.
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