"In PBGC's answer to 2004 Blue Book Q&A 2 item b, PBGC stated that a 1.411(a)-4(b)(6) forfeiture would not affect the inclusion of the participant in the flat rate premium count, but that it would result in the exclusion of the participant's benefit from the variable rate premium -- the reason being that IRS staff advised the PBGC that the benefit would be disregarded for current liability, and current liability was used for the variable rate premium. I understand this logic extends to the current environment where the relevant liabilities are (based on) target liability. Regarding the exclusion of these benefits from current liability and target liability, is anyone aware of where the IRS has actually opined on this or even mentioned it, other than the PBGC's statement in 2004 Blue Book Q&A 2? If they haven't opined, relying on the PBGC's statement might be aggressive. In this case, my follow-up question would be whether it might be objectionable to the IRS if I established a probability assumption for the reappearance of the participant (and consequent benefit reinstatement) -- where such probability might be very low if the participant was old, long gone, etc. (as it would reflect my expectations)."

[Sponsored]

Transform your future with Enterprise Iron! From strategic planning to tech optimization, we empower Financial, Retirement, & Gov’t. sectors. With 20+ years of success, see how we deliver results that matter. Discover more - read our stories today!

"What happens with the accounts in a SIMPLE IRA when it ends? Does each participant then just have their own IRA that they maintain indefinitely? I believe they can roll over that IRA to a qualified plan but not until 2 years after the SIMPLE IRA ended. Also, is there a standard form that needs to be presented to participants of a SEP IRA before the SEP IRA ends? Is there anything else the plan sponsor needs to execute. For example, when we terminate a qualified plan, an amendment needs to be executed before hand and if it is a pension plan then participants need to receive 204(h) notices beforehand."

"I received a QDRO that was filed by the court with judge's signature. The QDRO assigns $140,000 to the alternate payee as of Sep-19-2024, adjusted for investment gains and losses through the date funds are segregated. The problem is the participant's account balance as of the assignment date was only $125,000. Can we assume the QDRO's intent was to assign 100% of the participant's account balance as of the assignment date? And there has been a single $1,500 deposit for the participant since the assignment date, which is not subject to the QDRO and will remain in the participants' account +/- any gain or loss."