EOY-Valuations & Final Val

[JAY21]

Facts (simplified):

Calendar Year Plan terminates 8/31/08

All assets distributed by 10/31/08

Valuation Date: 12/31/08

I don't believe I am required to change to a BOY-Val. If I don't, is there any reason I can't just show zeroes (0's) on the Schedule B since my Fair Market Value of assets is $0 and my benefit liabilities as of 12/31/08 is $0 too ? The only reason I question it is that I had an accrual for 2008 which would produce a normal cost but on 12/31/08 all benefits and liabilities are $0. I don't think it would make sense to show a normal cost on the Schedule SB if all assets & liabilities are paid out before 12/31/08. Any thoughts ?

Is this another "no current guidance" question ? If so, opinions are still appreciated.

[david rigby]

1. Can you use a val date of 12/31/08 if the plan no longer exists? Would the correct val date be EOY = 10/31/08?

2. Why is a non-zero NC a problem?

[JAY21]

David, I suppose you're right on the val date changing to 10/31/08, but the issue then is still the same. To me if there is an accrual there is a normal cost, but with no assets or participants in the plan as of 10/31/08 is it ok to show $0 normal cost though there was an accrual ?

[david rigby]

IMHO, the existence of the NC is separate from the issue of the plan termination and distribution. I see no problem with showing a NC.