Effen Posted March 4, 2020 Posted March 4, 2020 It has been a long time since I had to allocate excess assets, and I couldn't find confirmation on this point. If a plan terminates during 2019, but doesn't allocate the excess assets until 2020, is the benefit increase attributed to the allocation of the excess treated as a benefit earned in 2019 or 2020? The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.
AndyH Posted March 4, 2020 Posted March 4, 2020 If at the time of plan term the plan had the language needed to allocate the excess, then I would think it would be 2019. If a post-termination amendment is needed, then I would think the amendment would specify. It could, for example, be needed for 11-g purposes. I don't see anything on the ACOPA board that expresses a different view, but there is not much directly on point (as you probably know). Since the allocation technically must be tested, I don't see how treating it as a 2020 allocation makes sense. Just one opinion.
Guy on a Limb Posted June 29, 2021 Posted June 29, 2021 If the Plan specifies reallocation of excess assets, does that prevent a transfer to the replacement plan? Which would mean an plan document election of a reversion would be required to have a transfer? Thank you
Mike Preston Posted June 29, 2021 Posted June 29, 2021 You asked the same question in another thread. I'm locking this one.
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