A defined benefit plan terminates with excess assets and is amended within the 60 day period prior to the plan termination date to provide a 5% pro-rata increase of participant benefits as of the termination date. The plan sponsor establishes a defined contribution plan as a qualified replacement plan and transfers into this plan the minimum amount necessary to lower the excise tax rate on any reversion to less than 50%. Selected data as of the asset distribution date: Market value of assets $2,100,000 Termination liability prior to 5% pro-rata increase $1,600,000X= the amount of the actual excise tax due from the employer. Y = the amount of the excise tax that would have been due had the qualified replacement plan not been established. In what range is X - Y ?
