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Posted

Hi

Setting a new plan effective 1/1/2023 and want to exclude service prior to inception for vesting purposes.

Prior plan was terminated during 2017, all assets distributed in 2018 (10/15/2018) and final 5500 was filed in 2019.

If I recall correctly, year of termination should be used i.e. 2017 and therefore plan termination was more than 5 years since 1/1/2023.

Thus, the new plan can exclude YOS for vesting prior to 1/1/2023.

Agree?

Happy holidays to all.

Posted

Does IRC 411(a)(4), and related regulations, have relevance?

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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