Peter Gulia Posted July 7, 2022 Posted July 7, 2022 An employer spins off from its 401(k) plan a portion of that plan’s assets and liabilities into an unrelated 401(k) plan. Neither the transferor plan nor the transferee plan has any defined-benefit or other pension obligation. On receiving the transferor’s Form 5310A, what does the IRS do with it. How likely is it that the IRS will ask the transferor a follow-up question? Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
CuseFan Posted July 7, 2022 Posted July 7, 2022 I had never had a DCP spin-off (or merger) that didn't meet one of the exceptions that exempted the transaction from filing. Maybe IRS will inquire about balance differences/unallocated accounts as a follow up, if they follow up at all, that would be my guess. Luke Bailey 1 Kenneth M. Prell, CEBS, ERPA Vice President, BPAS Actuarial & Pension Services kprell@bpas.com
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