jlea
Jun 7 2008, 08:48 PM
Pension plan money transferred into profit sharing plan, continues to be subject to QJSA/QPSA rules.
Does the plan need to be amended with respect to the mortality tables (i.e., RR 2001-62 re 94 GAR table; PPA 06 refinements)?
Blinky the 3-eyed Fish
Jun 11 2008, 10:00 PM
What kind of pension plan? I assume another DC plan. A DC plan doesn't have mortality tables specified it in and is therefore unaffected.
jlea
Jun 13 2008, 06:26 AM
Sorry - no - when I said pension plan, I meant a money purchase pension plan that is subject to the QJSA rules. So, of course, the transferred assets remain subject to the QJSA rules.
In any event, I found that the RMD amendment pulled in updated life expectancy rules.
And, based upon my research, it appears that the only provisions that tend to appear in DC plans that hold QJSA-subject assets are bare bones provisions regarding the continued application of QJSA/QPSA rules.
Makes me happy - the fewer provisions I have to worry about being appropriately included and amended, the better.