I think the 10% number bandied around is one possible approach to this problem. Perhaps more importantly, the level of surplus that a pension plan should properly hold should be related to the risks assumed by the plan. Depending on the nature of its asset mix, depending on the nature of its promises to plan participants, the riskier they are, the higher level of surplus it makes sense for the plan to target, either as a minimum prudential level of surplus or as a target surplus that the employer or the plan sponsor may choose to maintain.
I think the tax system certainly should not discourage the accumulation of those levels of surplus. The other issue of surplus ownership needs to...as well, it has been discouraging from companies--