PBGC owner only plan

[SSRRS]

Hi,

A DB Plan has been owner only (owner and wife) for approx. past ten years, but kept filing PBGC until now (showing only 2 participants each year). This year did not file and when contacted by PBGC it was explained to the agent that the plan is owner only since 2008 and a copy of the 5500 EZ was given to the PBGC (showing that it's an owner only plan). The agent agreed that the plan.is not covered anymore and emailed a convoluted form to fill out so that the plan can be removed from PBGC records. 1. The form has a box to check to confirm that a copy of plan document  is being included with the form...why do they want/need a copy of the plan document for this purpose?..2. They ask that if the spouse of the owner is a plan participant, was she an employee, director, or manager? Why is this relevant, doesn't attribution say that the spouse is an owner as well? This is an INC.

There is an attribution exception of non involvement. This means that the spouse has no involvement in the other spouse's business. However, in this case, since the wife is on the plan that means she is involved in her husband's business, as you can only be a plan participant if you are an employee of the sponsor. 3. So attribution should say that the wife is an owner? Thank you for any insight or ideas in regard to the best way to proceed with this. 

[david rigby]

Not trying to be snarky, but you may be overthinking this.  Just my opinion.

1.  Who cares why.  Answer the Q.

2.  Who cares about relevance.  Answer the Q.

3.  Yes.

[SSRRS]

Thank you David for your advice and time. As usual, you managed to set things straight in a clear concise way. Sometimes I do get bogged down, getting to analytical. Thank you, and may you be safe.