Quarterly contributions in year of plan termination

[AndyH]

Calendar year plan terminates 4/30/2014 and had a funding shortfall as of 1/1/2013. Assume assets are not distributed until 2015. MRC for 2013 was $100,000. MRC for 2014 is $50,000.

What are the quarterly installment dates for 2014 and what are the required quarterly amounts?

(Main question: Is this considered a "short plan year" for 430 purposes, and does that mean that $22,500 is due 4/15/14 and 5/15/14?). If not, do the same 4/15, 7/15, 10/15 and 1/15 dates and rules still apply with the quarterly amounts being $11,250?

[My 2 cents]

Had the plan not terminated, quarterly contributions would have been due 4/15/14, 7/15/14, 10/15/14 and 1/15/15. For what it is worth, It is my understanding that quarterly contributions are not required after the effective date of the plan termination, so the only quarterly amount required would be due 4/15/14. The minimum required contribution for the plan year still needs to be satisfied.

[AndyH]

Hmmm. Thanks for the feedback.

Anybody willing to agree or disagree with this interpretation? I have not found a consensus on this question - far from it.

[Rball4]

I guess my main question is 'does it matter'? Plan assets will need to be made sufficient prior to the final distribution, so wouldn't the aggregate contributions exceed the required quarterlies plus late interest anyway? Or is the plan only slightly under 100% funded?

[AndyH]

Yes, true, but it does affect the timing. If in the example I provided there is a short year for 430 purposes, and quarterlies are required, the second quarterly contribution is accelerated from 7/15 to 5/15. In the case of a large plan, there are employee and PBGC notices to consider.