Are there any exceptions to the general rule that any reimbursement of plan expenses by an employer will be considered an employer contribution? I have heard that an employer can reimburse the plan for the expense of getting out of certain annuity contracts without this being considered an employer contribution, and that this is "done all the time." Does anyone know of a letter ruling or some other guidance that indicates that this is true?

There aren't any exceptions. What is commonly done to avoid the situation when a plan is moved and liquidation triggers back end loads, the employer instructs the liquidating fund company to not charge the loads but instead bill the company. The company then remits a check outside the plan directly to the fund company.