Demo 7 of Schedule Q - Nondiscriminatory Past Service Credits

[Guest Ted H Munice]

Does anyone have experience with the IRS concerning Demo 7 of Schedule Q - Nondiscriminatory Past Service Credits? We have a plan converting to a cash balance format with a provision to provide an opening cash balance equal to the greater of the present value of the old accrued benefit or the theoretical cash balance as if it was in place for all prior years. As this is an increase in a past service benefit (for some)I assume we have to satisfy the nondiscimination regs and complete Demo 7. Does anyone have experience with the IRS on what criteria the Service considers when ruling on this "facts and circumstances" test?