Form 5310

[JustnERPA]

Suppose plan A merges into plan Z. Plan A files a Final 5500 and shows the transfer amounts to plan Z. Also suppose Plan A uses a pre-approved document. Can Plan A file a Form 5310 to get a determination for its final year?

[Luke Bailey]

I don't think so, since it is not terminating. However, under Rev. Proc. 2019-20 the plan that results from the merger (aka, "surviving plan") can apply for a DL if the reason for the plan merger was an acquisition-type transaction by the sponsoring employers. The deadline for the submission is the end of the first plan year following plan year in which the employer acquisition-type transaction occurred.