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Defined benefit plan termination


Belgarath

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Sal's EOB states that there is an IRS 6-month extension from the date of the IRS determination letter to make the distributions.

I am absolutely unable to find a Revenue Ruling or citation, IRS form or publication, newsletter, etc., that supports this. Does anyone know if this statement is correct? Did the IRS state this at a conference or is it in the actuary "gray book" questions somewhere, etc.?

The PBGC instructions give 120 days, but not 6 months.

Thanks!

P.S. I e-mailed Sal with this question as well - I'll post his response if he gets back to me.

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Page 15.835 (g) of the 2012 editions. Has been in prior editions as well.

Sal got back to me and said that he can't find his source for this statement either. I'm sure he had a good reason for it way back when, but he can't recall what it was. He'll be fixing this in the future.

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It doesn't say 6-month extension from the date of the IRS determination letter. It says 180 days from the PBGC's 60-day comment period on the Form 500 filing or 120 days after determination letter is received (if later than the normal 180-day deadline) if the determination letter request was filed no later than the time the standard termination notice was filed with the PBGC. This language corresponds to the time line chart on the page 3 of the PBGC Form 500 instruction.

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In fact, it does specify what I said. You are talking about a plan subject to PBGC. I wasn't. However, since I didn't specify this in the original post, your confusion is understandable. Look under the first part of (g) under the one-year rule.

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