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Guest steve dolce
Posted

a plan sponsor reverts 75% of the plan's excess assets in february but does not make the transfer to the qualified replacement plan until much later. what kind of problems does he have?

  • 4 weeks later...
Posted

Can you give some more specific timing (you said that 75% went to employer in February, I assume 25% to replacement plan not yet transferred until "much later" - this is March so I wouldn't call that too much later at this point :) . The excise taxes due on the net employer reversion are due by the end of March so you still have time to pay these (if not already done). Please outline the years you're talking about here (one could possibly construe that the 25% remaining in the prior plan trust is effectively in the new trust and gets these earnings - I don't think the IRS would give you much trouble here). Unless of course your February is in 1999 and transfers occurred in 2000. More detail please.

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