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Posted

Does anyone have any thoughts on the meaning of "offset arrangement" on the Form 5300?  We've got a defined benefit plan that offsets benefits by the benefits under another defined benefit plan.  (There are complicated reasons for this structure.)  I'm seeing lots of discussion that a "floor offset" plan involves only a DB plan that is offset by a DC plan, not by another DB plan.  But I can't find a specific definition of "offset arrangement," without the "floor" part.

Employee benefits legal resource site

The opinions of my postings are my own and do not necessarily represent my law firm's position, strategies, or opinions. The contents of my postings are offered for informational purposes only and should not be construed as legal advice. A visit to this board or an exchange of information through this board does not create an attorney-client relationship. You should consult directly with an attorney for individual advice regarding your particular situation. I am not your lawyer under any circumstances.

Posted

Just thinking out loud, any possibility your 2 plans are (or should be) treated as one plan for 5300 purposes (and maybe 5500 purposes)?

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

Posted
1 hour ago, david rigby said:

Just thinking out loud, any possibility your 2 plans are (or should be) treated as one plan for 5300 purposes (and maybe 5500 purposes)?

No.  One of those single employer plan offset by multiple employer plan things.

Employee benefits legal resource site

The opinions of my postings are my own and do not necessarily represent my law firm's position, strategies, or opinions. The contents of my postings are offered for informational purposes only and should not be construed as legal advice. A visit to this board or an exchange of information through this board does not create an attorney-client relationship. You should consult directly with an attorney for individual advice regarding your particular situation. I am not your lawyer under any circumstances.

Posted
1 minute ago, PensionPro said:

The IRS has been known to use the terms "floor offset" and "offset" plans interchangeably.

Thanks--good to know!

Employee benefits legal resource site

The opinions of my postings are my own and do not necessarily represent my law firm's position, strategies, or opinions. The contents of my postings are offered for informational purposes only and should not be construed as legal advice. A visit to this board or an exchange of information through this board does not create an attorney-client relationship. You should consult directly with an attorney for individual advice regarding your particular situation. I am not your lawyer under any circumstances.

Posted

In the past, in similar circumstance, I checked yes and added the simple description of the offset of benefits provided by the other plan. 

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

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