Do we need to know the pre-2011 values for the transition rules under IRC 430 and 417(e)?
There are several transition rules under IRC 430 and 417(e). The IRC 430 transition rules expired starting with the 2011 plan year. The 417(e) transition rule for the applicable interest rate DOES NOT EXPIRE until the 2012 plan year. You do NOT need to know the OLD transition rules, or know all the law history. In the 2011 Joint Board announcement, it states the exam is based on the law in effect at May 31, 2011. It is remotely possible there might be a 2011 problem which gives you 2010 valuation results, and where the shortfall base exemption using the applicable percentage of 96% applies. That is the only historical item I anticipate they would test in 2011.
