Alex Daisy
Jun 10 2009, 11:43 AM
Can someone tell me who i should report on this line?
The instructions read "Include any individual who terminated employment during this plan year, whether or not he or she (a) incurred a break in service, (b) received an irrevocable commitment from an insurance company to pay all the benefits to which he or she is entitled under the plan, and/or (c) received a cash distribution or deemed cash distribution of his or her nonforfeitable accrued benefit. Multiemployer plans and multiple-employer plans that are collectively bargained do not have to complete line 7h."
Do I include anyone who terminated in 2008 and is not 100% vested? What if they were paid out also in 2008, do I include them?
Any guidance is greatly appreciated.
J Simmons
Jun 10 2009, 12:00 PM
QUOTE
Do I include anyone who terminated in 2008 and is not 100% vested?
Yes for anyone who had any accrued benefits and was not 100% vested when he or she terminated employment in 2008.
QUOTE
What if they were paid out also in 2008, do I include them?
Yes.
Santo Gold
Jul 7 2009, 12:51 PM
A participant does not have an account balance (never deferred and the only ER contributions are match contributions) and terminates employment. Participant would have been 0% vested in the ER contribution. Would you include this participant on line 7(h)?
Thanks
Santo Gold
Jul 7 2009, 12:55 PM
QUOTE (Santo Gold @ Jul 7 2009, 01:51 PM)

A participant does not have an account balance (never deferred and the only ER contributions are match contributions) and terminates employment. Participant would have been 0% vested in the ER contribution. Would you include this participant on line 7(h)?
Thanks
Found a previous discussion on this. Not sure I agree though
http://benefitslink.com/boards/index.php?showtopic=31387
Below Ground
Jul 7 2009, 03:15 PM
I suggest that it boils down to what does "deemed distribution" mean. I would count both since it is safer to do, in my opinion.
BG5150
Jul 7 2009, 03:16 PM
I've always wondered what the point to the question is. Why does the govn't care how many people left who were not 100% vested? Are they keeping track somewhere, and when the ratio of all the plans is high enough they will mandate more liberal vesting schedules?
TPAMan
Jul 8 2009, 01:55 PM
I always thought they used it as a proxy for possible partial plan terminations.
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