Determination Letter Application

[Guest MJ1]

I understand that an employer who has adopted a VS Plan that is covered by a favorable opinion letter may apply for a determination letter upon its termination by filing a 5310 (as opposed to a 5307). Assuming the VS plan is up to date as of its termination, am I correct in understanding that the employer may file a 5310 and that the VS plan's cycle is not relevant? If an amendment is necessary, does the plan convert to IDP status for purposes of the submission?

[Guest Sieve]

All amendments that must be in place for a terminating plan (i.e., generally all that are effective prior to the termination date) will be required, regardless of cycle. It is still considered a VS plan when terminating (at least that's how I've always treated them).