Change in valuation date

[Guest lerieleech]

If a small plan has a 12/31 valuation date for calendar year 2007, can it switch to a 1/1 val date for 2008?

It appears to me that PPA 06 Sec. 302(d)(1) takes away the automatic approval to a BOY val date that was in Rev. Proc. 2000-40. But looking onward in PPA 06, I'm not sure this isn't allowed in this case.

[AndyH]

If a small plan has a 12/31 valuation date for calendar year 2007, can it switch to a 1/1 val date for 2008?

It appears to me that PPA 06 Sec. 302(d)(1) takes away the automatic approval to a BOY val date that was in Rev. Proc. 2000-40. But looking onward in PPA 06, I'm not sure this isn't allowed in this case.

Yes, for 1/1/2008. After that, there is currently no automatic approval.

This is in PPA, and it is clearer in one of the regs, plus David Ziegler of IRS confirmed it on the phone with me. This provision of RP 2000-40 is obsolete for single employer plans.

p.s. The cite he gave me is Prop reg 430(d)-1(g)(3)

[JAY21]

Andy, so is it your take that Rev. Proc. 2000-40 is still good for 2007 PYEs but obsolete for 2008 plan years (plan years beginning in 2008) ?

[AndyH]

That specific provision, and it's applicablity to single employer plans, yes. I actually couldn't get him to bite on the word "obsolete", just that the proposed reg was now considered "the authority", plus he agreed there was no automatic approval (at least for single ER plans) after 2008.