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Here is the issue: Employer has one non-union and three union defined benefit plans. The non-union DB plan is overfunded by a substantial amount while the union DB plans are underfunded. Employer would like to transfer some of the excess assets from the non-union DB plan to the various union DB plans? Has anyone advised a client on this issue and, if so, did your client obtain IRS approval of such a transfer vis a vis a private letter ruling?

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