AFTAP & Deemed Burn Timing

[JBones]

AFTAP for 2009 is certified based on 12/31/2008 valuation to be 89.54% on 9/30/2009.

2010 AFTAP is not certified until September 28, 2010 based on 12/31/2009 valuation. On 4/1/2010 the presumed 2010 AFTAP is deemed 10% lower than the 2009 AFTAP and a restriction would apply because it is now below 80% - but there was a carryover balance that when reduced brings it back up to 80% ($219 reduction).

Per the preamble to the regulations, the election is treated as having been made on the new AFTAP measurement date - 4/1/10.

When is this reduction treated as having occured? The reduction was based on the assets, FT and COB as of the 2008 valuation, so do I have to amend the 2008 SB to show the reduction occuring in that year (which would change my other valuation calcs such as shortfall) or does it show up on the SB line 12 for 2009 or 2010?

Some of these PPA timing issues have me completely lost.

[JBones]

I'll try to shorten the question.

The AFTAP for a plan using an end of year valuation date is not certified by 4/1/2010 which causes the 2010 AFTAP to be deemed 10% lower than the 2009 AFTAP, drop is from 89% to 79%. A carryover balance exists and is deemed burned at that time in order to avoid restrictions.

At what date is the burn treated as occuring?

[Mike Preston]

4/1/2010, but as of 1/1/2010. You will not change anything on a 2009 government report.

[JBones]

Thanks Mike.