| | 92-1 |
| | March 30, 1992 |
| | REFERENCE: |
| | >4001(b)(1)> |
| | 4203 Complete Withdrawal |
| | 4204 Sale of Assets |
| | 4204(a)(1) Sale of Assets. Conditions for Exemption from Withdrawal |
| | 4205 Partial Withdrawals |
| | >4205(b)(1)> |
| | 4206 Adjustment for Partial Withdrawal |
| | 4211 Withdrawal Liability |
| | 4212(c) Obligation to Contribute - Liability |
| | 4218 Withdrawal - No occurrence |
| | OPINION: |
| | I write in response to your letter requesting the opinion of the Pension Benefit Guaranty Corporation ("PBGC") in regard to |
| | calculating liability for a complete or partial withdrawal under Sections 4203 and 4205 of the Employee Retirement Income |
| | Security Act of 1974 ("ERISA"), as amended, 29 U.S.C. § § 1383 and 1385 (1989). Specifically, your question concerns |
| | the calculation of withdrawal liability in a situation where several members of a controlled group of corporations have an |
| | obligation to contribute to the same rultierployer pension plan and the controlled group members are sold or liquidated in a |
| | series of transactions. |
| | As you are aware, Section 4221 of ERISA provides that disputes between a plan sponsor and an employer on issues |
| | concerning withdrawal and withdrawal liability are to be resolved first through arbitration, and, if necessary, in the courts. |
| | The PBGC does not interject itself into these statutory procedures by issuing opinions on the application of the law to |
| | particular transactions. However, the PBGC will continue its practice of answering general questions of interpretation under |
| | Title IV of ERISA. |
| | In the hypothetical situation you present in your letter, parent company P has four wholly-owned subsidiaries, A, B, C and |
| | D. The four subsidiaries contribute to a multiemployer pension plan (the "plan") in equal periodic amounts under a single |
| | collective bargaining agreement. |
| | In a series of transactions, P's controlled group ceases covered operations at each of the subsidiaries. First, P closes |
| | subsidiary A and does not continue operations previously performed by A. Second, P sells the assets of subsidiary B to |
| | an unrelated purchaser. The purchaser does not assume B's contribution obligation or make contributions to the Plan. |
| | Third, P sells the stock of subsidiary C to another unrelated purchaser. C continues in business and makes required |
| | contributions to the plan. Finally, P sells the stock of subsidiary D to a third unrelated purchaser. D continues operations |
| | and contributes to the plan for several years before going out of business. You request the PBGC's opinion as to the |
| | assessment of liability for a complete or partial withdrawal stemming from this series of transactions. |
| | For purposes of determining whether a complete or partial withdrawal has occurred, all trades or businesses under common |
| | control are to be treated as a single employer. ERISA § 4001(b)(1), 29 U.S.C. § 1301(b)(1). Under Section 4203(a) of |
| | ERISA, 29 U.S.C. § 1383(a), a complete withdrawal generally occurs when an employer permanently ceases to have an |
| | obligation to contribute under a plan, or permanently ceases all covered operations under a plan. A partial withdrawal |
| | generally occurs when an employer has a 70% contribution decline in each of three consecutive plan years; or, the |
| | employer permanently ceases to have an obligation to contribute under one or more but fewer than all collective bargaining |
| | agreements, but continues to perform work in the jurisdiction of the collective bargaining agreement of the type for which |
| | contributions were previously required, or transfers such work; or, the employer permanently ceases to have an obligation |
| | to contribute with respect to work performed at one or more but fewer than all of its facilities, while continuing to perform |
| | work at that facility of the type for which the obligation to contribute ceased. ERISA § 4205(a) and (b), 29 U.S.C. § |
| | 1385(a) and (b). The methods for computing the amount of liability for a complete or partial withdrawal are set forth in |
| | Sections 4211 and 4206 of ERISA, 29 U.S.C. § § 1391 and 1386. In order to determine whether a complete or partial |
| | withdrawal has occurred and the amount of the resulting liability, contributions of the entire controlled group must be taken |
| | into account. 29 U.S.C. § § 1301(b)(1) and 1391. |
| |
As you point out in your letter, when subsidiary A is closed in the first transaction, there is no complete or partial |
| |
withdrawal by the controlled group. Three members of the controlled group continue to have an obligation to contribute to |
| |
the plan and continue covered operations. There is no partial withdrawal because, on the facts assumed, there has not |
| |
been a 70% decline in contributions by the controlled group over a three-year period or a partial cessation of the controlled |
| |
group's contribution obligation within the meaning of Section 4205(b)(2)(A) of ERISA, 29 U.S.C. § 1385(b)(2)(A). Thus, for |
| |
purposes of calculating the amount of liability for a subsequent complete or partial withdrawal under Sections 4211 and |
| |
4206 of ERISA, 29 U.S.C. § § 1391 and 1386, A's contribution history remains part of the controlled group's contribution |
| |
The same holds true on the sale of B's assets to an unrelated purchaser. Even though the asset sale is not structured to |
| |
meet the requirements of Section 4204 of ERISA, 29 U.S.C. § 1384, there is no complete or partial withdrawal because |
| |
two other members of the controlled group continue to contribute to the Plan and there has been no 70% decline in |
| |
contributions over three years or any partial cessation of the controlled group's contribution obligation under 29 U.S.C. § |
| |
1385(b)(2)(A). Again, the contribution history of B remains part of the controlled group's contribution history for purposes |
| |
of calculating amounts of subsequent withdrawal liability. |
| |
The sale of the stock of subsidiary C to an unrelated purchaser that continues to make contributions to the plan would |
| |
ordinarily fall within the ambit of Section 4218 of ERISA, which provides in relevant part: |
| |
Notwithstanding any other provision of this part, an employer shall not be considered to have withdrawn from a plan solely |
| |
because -- |
| |
(1) an employer ceases to exist by reason of -- |
| |
(a) a change in corporate structure described in Section 4069(b) . . . |
| |
if the change causes no interruption in employer contributions or obligations to contribute under the plan . . . . |
| |
* * * |
| |
[A] successor or parent corporation or other entity resulting from any such change shall be considered the original |
| |
29 U.S.C. § 1398. |
| |
Among the changes described in Section 4069(b) of ERISA, 29 U.S.C. § 1369(b), are "a mere change in identity, form, or |
| |
place of organization" and "a merger, consolidation or division." In Opinion Letters 82-4 (February 10, 1982), 83-11 (May 16, |
| |
1983), and 84-7 (December 20, 1984), the PBGC expressed its opinion that the sale of a subsidiary's stock does not bring |
| |
about the withdrawal of the parent corporation, if the change causes no interruption in employer contributions or obligations |
| |
to contribute under the plan. |
| |
Under the last sentence of Section 4218 of ERISA, a successor employer resulting from a restructuring described in that |
| |
Section is considered the "original employer." This provision attributes the contribution history of the original employer to |
| |
the successor employer resulting from the restructuring. In the typical case, the contribution history used to determine the |
| |
withdrawal liability of the successor will be the contribution history that would have formed the basis for withdrawal liability |
| |
if the restructuring had not occurred. |
| |
In your hypothetical, the sale of C's stock causes no interruption in contributions or obligations to the plan. C and its new |
| |
controlled group, if any, and the P controlled group, continue to contribute to the Plan. Consequently, there is no complete |
| |
withdrawal by the P controlled group, or by C and its new controlled group, if any. Pursuant to the last sentence of |
| |
Section 4218, both the P controlled group and C and its new controlled group, if any, are "successor" employers. |
| |
However, in a situation such as this where multiple entities in the same controlled group contribute to the same plan, and |
| |
some, but not all, of the controlled group members who contribute to the plan are the subject of a change described by |
| |
Section 4218 of ERISA, neither of the successors clearly should inherit the entire contribution history of the original |
| |
employer. In such a case, it is the PBGC's opinion that the contribution history of the original employer must be fully |
| |
apportioned among the successor employers. The plan should make the allocation in a reasonable manner. For example, |
| |
in the absence of a history of large transfers of operations or covered employees between members of the controlled |
| |
group, or other unusual factors, the plan may allocate that contribution history in proportion to the contribution histories of |
| |
the controlled group members that have an obligation to contribute and covered operations immediately before the Section |
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4218 transaction, or in your hypothetical 50% to C and 50% to the P controlled group. |
| |
Consequently, in the event of a subsequent complete withdrawal by the P controlled group, the amount of liability under |
| |
Section 4211 of ERISA, 29 U.S.C. § 1391, is determined without reference to the contribution history allocable to C and |
| |
its new controlled group, if any. Likewise, in the event of a subsequent complete withdrawal by C and its new controlled |
| |
group, if any, the amount of liability under Section 4211 of ERISA, 29 U.S.C. § 1391, is determined without reference to |
| |
the contribution history allocable to the P controlled group. |
| |
You also inquired as to the effect of the sale of C's stock on determining whether a partial withdrawal occurs under Section |
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4205(a)(1) of ERISA, 29 U.S.C. § 1385(a)(1). Under your hypothetical, once C is sold, the contributions of the P |
| |
controlled group decline by 75%. Generally, a partial withdrawal occurs whenever there is a 70% contribution decline in |
| |
each of three consecutive plan years measured against a base year. See 29 U.S.C. 1385(b)(1). Under Section 4218 of |
| |
ERISA, P's controlled group would not ordinarily incur a partial withdrawal in the third plan year following the sale of C's |
| |
stock. However, in order to avoid partial withdrawal liability, the decline in contributions must be "solely" because of a |
| |
covered change in corporate structure. 29 U.S.C. § 1398. |
| |
In your hypothetical, it is not clear whether the decline in contributions is solely because of the sale of C's stock. The |
| |
decline could be due, at least in part, to closing A and selling the assets of B to a purchaser who did not continue making |
| |
contributions to the Plan. Whether a decline in contributions is solely because of a covered restructuring must be |
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determined on the facts and circumstances of each case and should be addressed by arbitration subject to review by the |
| |
courts. Relevant considerations might include the length of time between transactions, whether the transactions were |
| |
related, and whether each transaction would have been subject to Section 4218 if viewed individually. |
| |
If the decline in contributions is determined to be solely because of the sale of C's stock, the contribution history |
| |
transferred in the Section 4218 transaction is excluded from the base year calculations used to determine whether a 70% |
| |
decline has occurred under Section 4205(b)(1)(B)(ii) of ERISA. If the decline in contributions is determined not to be solely |
| |
because of the sale of C's stock, C's contribution history is included in the base year calculations. |
| |
In the final transactions D's stock is sold to a third unrelated purchaser who continues making contributions to the Plan on |
| |
behalf of D's employees. After the stock sale, the P controlled group ceased covered operations and no longer has an |
| |
obligation to contribute to the Plan. Under Section 4218 of ERISA, the P controlled group would not ordinarily be subject to |
| |
withdrawal liability on the sale of D's stock. As stated above, however, in order to avoid withdrawal liability, the controlled |
| |
group must cease to have such operations or such obligations "solely" because of a covered change in corporate |
| |
structure. 29 U.S.C. § 1398. As discussed above, whether an employer's cessation is solely the result of a covered |
| |
restructuring must be determined on the facts and circumstances of each case and should be addressed by arbitration |
| |
subject to review by the courts. |
| |
Assuming that the controlled group's cessation is not solely because of a covered restructuring, it incurs a complete |
| |
withdrawal. However, D and its new controlled group, if any, would be a "successor" within the meaning of the last |
| |
sentence of Section 4218. Consequently, a portion of the P controlled group's remaining contribution history must be |
| |
allocated to D and its new controlled group, if any, under the principles discussed above. The P controlled group's liability |
| |
is then determined pursuant to Section 4211 of ERISA, 29 U.S.C. § 1391, based on the contribution history of the original |
| |
employer that was not transferred to C or D. C and its new controlled group, if any, remains responsible for the |
| |
contribution history previously allocated to C. |
| |
Alternatively, if the controlled group's cessation is determined to be solely because of a covered restructuring, the |
| |
controlled group is not subject to withdrawal liability even though it no longer has an obligation to contribute to the Plan or |
| |
has covered operations under the Plan. In that event, D and its new controlled group, if any, inherits the contribution |
| |
history of the P controlled group that was not allocated to C. |
| |
You also ask if the result would be different if the assets of D are sold in a transaction that meets the requirements of |
| |
Section 4204 of ERISA, 29 U.S.C. § 1384. Under Section 4204(a)(1) of ERISA, an employer will not incur liability for a |
| |
complete or partial withdrawal "solely" because of the sale of all or a portion of its assets to an unrelated purchaser if the |
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following conditions are met. First, the purchaser must have an obligation to contribute to the pension plan for |
| |
substantially the same number of contribution base units as the seller. Second, the purchaser must provide a cash or |
| |
surety bond payable to the pension plan in the five years after the sale if the purchaser withdraws or fails to make |
| |
required contributions. Third, the contract for sale must provide that if the purchaser withdraws in the five years after the |
| |
sale and fails to pay its withdrawal liability, the seller is secondarily liable. 29 U.S.C. § 1384(a)(1). |
| |
Under Section 4204(b)(1) of ERISA, 29 U.S.C. § 1384(b)(1), the liability of the purchaser for a subsequent complete or |
| |
partial withdrawal is determined as if the purchaser was required to contribute to the plan the amount the seller was required |
| |
to contribute for the operations transferred for the year of the sale and the four previous years. Thus, the purchaser |
| |
assumes the contribution history of the seller for the year of the sale and the four plan years preceding the sale, but only |
| |
for the contribution history relating to the assets transferred in the sale. |
| |
In your hypothetical, if the assets of D are sold in a sale that meets the requirements of Section 4204 of ERISA, the P |
| |
controlled group has ceased covered operations and no longer has an obligation to contribute to the Plan. Like the sale of |
| |
stock situation discussed above, the P controlled group would not ordinarily be subject to withdrawal liability on the sale of |
| |
D's assets. However, under Section 4204(a)(1), as under Section 4218, in order to avoid withdrawal liability, the controlled |
| |
group's cessation must occur "solely" because of a sale of assets. Again, the question of whether an employer's |
| |
cessation is solely because of a particular transaction must be determined on the facts and circumstances of each case |
| |
and should be addressed by arbitration subject to review by the courts. |
| |
Assuming that the controlled group's cessation is solely because of the asset sale, the controlled group does not incur |
| |
withdrawal liability even though it no longer has an obligation to contribute to the Plan or has covered operations under the |
| |
Plan. However, the controlled group is secondarily liable if D and its new controlled group, if any, withdraw from the Plan |
| |
within 5 years of the asset sale and fail to make withdrawal liability payments. D and its new controlled group, if any, |
| |
assume the contribution history relating to D's operations for the year of the sale and the previous four years. |
| |
If the controlled group's cessation is determined not to be solely because of the sale of D's assets, it incurs a complete |
| |
withdrawal and its liability is determined pursuant to Section 4211 of ERISA, 29 U.S.C. § 1391, based on the contribution |
| |
history of the original employer that was not transferred to C. |
| |
As a final matter, the opinions in this letter are subject to the special rule in Section 4212(c) of ERISA, which states: |
| |
If a principal purpose of any transaction is to evade or avoid liability under this part, this part shall be applied (and liability |
| |
determined and collected) without regard to such transaction. |
| |
29 U.S.C. § 1392(c). Depending on the facts, some of the same considerations as are relevant in determining whether a |
| |
cessation is due "solely" to a restructuring or sale of assets may be relevant under Section 4212(c). |
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I hope this has been of assistance to you. If you have any further questions, please call D. Bruce Campbell of my staff |
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at (202) 778-1918. |
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Carol Connor Flowe |
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General Counsel |