IRS PLR: Surplus Assets Transfer from Terminated Defined Benefit Plan to Qualified Replacement Plans Avoids Excise Tax (I.R.C. §4980)

The IRS has published a private letter ruling on I.R.C. §4980 allowing a taxpayer to transfer surplus assets from a terminated defined benefit plan to two defined contribution plans treated as a single qualified replacement plan, avoiding the excise tax on reversions while requiring ratable allocation from suspense accounts over a seven-year period. [PLR 202550025]

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