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Plan Compensation limited


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I remember that after PPA, the plan termination date was to be treated as a plan year end and certain items had to be pro-rated (compensation, deferrals and such).

Now I cannot find ANYTHING that backs up my memory! Not only that, I am being challenged by an attorney.

HELP!!!! Thanks all.

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with a caveat
at the 2010 ASPPA Conference Q and A 3, in regards to a terminated plan and top heavy the IRS person indicated the following:
(1) Of course, if there is no employer contribution, there would not be an obligation to provide top
heavy minimum contribution. But, if there were contributions to keys during the year, including
elective deferrals, there is a top heavy minimum based on compensation and employment
through 9/15/10. Plan must liquidate within a reasonable time under Rev. Rul. 89-87 or else
9/15 date may not be reasonable
. There is effectively a short plan year for top heavy purposes.

in other words, if the assets aren't paid out then you could lose the 'short plan year'

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