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Terminated Plan's Assets Rolled into New Plan Under Same Controlled Group -- Related or Unrelated for Top Heavy Testing?
BenefitsLink Message BoardsLink to more items from this source
May 12, 2021

"Two employers (A and B) in the same controlled group have separate plans (Plan A and Plan B). Plan A terminates because employer A shuts down and many participants start working for employer B. Most participants roll assets from terminated Plan A into Plan B. Plan B has predecessor language for eligibility and vesting for participants from Plan A. They were given opportunity to take their balance or rollover to IRA or another qualified plan. Are the rollovers from Plan A into Plan B considered 'related' rollovers for top-heavy testing?"

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