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Posted

The new funding relief provides a 2 and 7 rule or the 15 yr amort rule.

The question is:

Say the rellief is used for a 2009 cal yr plan.

Does this relief apply to a new amort base or does it apply to the entire funding shortfall including bases established in 2008?

my impression is that you take the entire shortfall and apply it and not just the new base.

thanks

Posted

Look at Act section 201(b)(1), modifying IRC 430©:

"... with respect to the shortfall amortization base of a plan for any eligible plan year..." implies that the change is only for the base created in a particular year.

Other interpretation may be valid. Is that how you read it?

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

  • 1 year later...
Posted

Now that the funding relief has been in effect for a while is it still interpreted that it is based on only the particular year and not the total funding shortfall?

I will look over notice 2011-3 as well.

thanks

Guest Quagmire
Posted
Now that the funding relief has been in effect for a while is it still interpreted that it is based on only the particular year and not the total funding shortfall?

I will look over notice 2011-3 as well.

thanks

It's for the base established in a particular year. See Notice 2011-3 Q&A G-2.

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