Line 4d of 5300 - plan's original effective date

[fiona1]

I am completing Form 5300 for a plan that spun-off on 1-1-2008. On line 4d it says to put the plan's original effective date. I assume this would be the effective date of the original plan - and that I shouldn't put 1-1-08 - Correct?

I also have to indicate on line 3b if the plan has received a determination letter. The spun-off plan obviously has not - but the other plan has. I assume I should indicate yes and notate the date of the determination letter of the original plan?

Of course I can't find any guidance on how to complete 5300's on spin-off plans. Any thoughts?

[jpod]

I disagree on both counts. The spin-off construct under Section 414(l) of the Code is a transfer of assets from one plan to another. In other words, it is treated as if a new plan with no assets existed for an instant in time, and then a transfer of assets and liabilities was made from the original plan to that new plan. Therefore, I think the ED is 1/1/08 and there is no determination letter.

[DMcGovern]

The 5300 is for the spin off plan, not the other plan. ED is 1/1/08 and no determination letter