Two Plans with different Plan Year Ends

[Dougsbpc]

Suppose you have a professional employer who has sponsored a Defined Benefit Plan and a Profit Sharing Plan, both with a December 31 plan year. There are eight participants in each plan. The arrangement has worked well for over 10 years.

The defined benefit plan is becoming over funded so they should terminate that plan as soon as possible. If the Defined Benefit Plan is terminated effective 7/15/2026 all participants would have accrued a benefit in 2026 because they all would have worked more than 1,000 hours by that time. Not a problem. However, I believe the Defined Benefit Plan would then be deemed to have a short year for 2026 (1/1/2026 - 7/15/2026). Can the 7/15/2026 Defined Benefit Plan be cross-tested with the 12/31/2026 Profit Sharing Plan?

We can wait to terminate the Defined Benefit Plan until year end but then we may be waiting around just watching that plan becoming more and more over-funded.

Unless there is some prohibition in doing so, it should be easy enough to test the 7/15/2026 DB with the 12/31/2026 PSP. After all, participants have already accrued 2026 benefits in the DB plan and most will receive at least 7.5% of salary contributions in the PSP.

Thanks.