"So, you have Plan A sponsored by Employer A. Employer B signs on as a participating employer, but not a CG/ASG and thus a MEP. Plan B winds down to one employee. Plan B is supposed to spin off, and then immediately terminate plan. Plan B employer never signs the paperwork to do this, and in the meantime, the one employee terminates employment, and the distribution is processed by plan A, where the assets were held. The question is, does the spinoff still need to happen, and a first and final 5500 form be filed for Plan B? There are no assets to spinoff, and the temptation is strong to just ignore it, but it feels all wrong. Anyone ever encountered such a situation?"

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"If erroneous pension annuity payments from a defined benefit plan (no beneficiary or joint and survivor annuity at issue) are made following a retiree's death due to late death notification and the plan administrator is unable to recoup from the estate, would a 1099-R be issued to the estate (no information is available as to estate tax id)? Is there a way to adjust the withholding that was submitted on future deposits or obtain a refund of the withheld amount -- through a 945-X (although instructions state it's limited to clerical errors) or other means -- because no party had a legally binding right to the payments after death? This has to be a common scenario, yet I haven't found guidance directly addressing the death overpayment situation (only guidance addressing overpayments to living retirees/participants)."