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Partial Plan Termination & Reinstate Forfeitures


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If participants who are "affected" by a partial plan termination in a DC plan have already taken a distribution from the plan and the amount the participant previously forfeited needs to be reinstated to their account, should the amount reinstated be adjusted for investment earnings?

I don't consider this to be a "mistake" that necessitates investment earnings, but perhaps the IRS would disagree.

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