Is Form 5310-a necessary for DB surplus transfer to QRP?

[cheersmate]

Terminated DB distributed all participant benefits, satisfying all benefit liabilities.

Rather than pay surplus excise tax, the surplus will be transferred to a qualified replacement plan. Then allocated to participants (same as DBP participants).

Is Form 5310-A necessary?

[chc93]

ERISA attorney told us "no".

[cheersmate]

Thank you for replying. How did you reflect it on the 5500s (transferor and transferee) and did the plans involved receive any subsequent inquiries from IRS?  

I saw your previous posts on this a few years ago... what happened w that audit or IRS review?

Thank you again!

[chc93]

On the DB 5500, entered the amount transferred to the QRP as "Transfers to (from) the plan.  And listed the DC plan name, EIN, and PN in the section on transfers from the DB plan.

We did not work with the DC plan.  The DC 5500 showed the transfer from the DB plan as "Transfers to this plan" (goit this from EFAST online).  Don't know if there were inquiries or issues from the IRS with the asset transfer.

The DB plan got an IRS DL for the plan termination, and went through both IRS and PBGC plan termination audits successfully without inquiries or issues on the transfer of assets to the QRP.

[cheersmate]

Thank you, chc93.