Can a pre-1987 carryforward be used by a plan other than the plan that

[John A]

If a plan has a pre-1987 carryforward for deductibility purposes, and that plan has been terminated, may the employer use that pre-1987 carryforward in a subsequent plan (for example, money purchase plan terminates, plain vanilla profit sharing plan starts - can the profit sharing use the pre-1987 carryforward from the money purchase)?

[MR]

I would think not. Why would your scenario be different from an employer that had no plan prior to '87? You also have different deduction limits with MPP vs P/S. I seem to recall that in order for carryforwards to be allowed, it would need to be from the same plan.

[John A]

Thanks, MR. As I looked at Code Section 404, it seems to me that the pre-87 carryforward only applies to profit sharing and stock bonus plans anyway, and not to pension plans. It was a little less clear to me whether or not you could use the pre-87 carryforward from a stock bonus plan that had been terminated if a profit sharing plan had subsequently started, especially if the same trust was used for both plans. I don't see a specific requirement that it be the same plan, although that would make sense to me. Any other thoughts?