tmills
Jul 14 2006, 09:35 AM
It seems accepted that if a 4975(e)(2) disqualified person exercises a put option, the plan has to obtain a current stock value to make the payment. The question is, does the current value requirement only apply to the put option or any cash distribution of shares in a disqualified person's account? 54.4975-(11)(d)(5) says in the case of a transaction between the plan and a disqualifed person, value must be determined as of the date of the transaction. That would seem to require any payment made to a disqualified person for his shares not be done until a current value is obtained. I don't recall seeing this in documents (except relating to the put option), but we know that doesn't necessarily mean anything. Any thoughts would be appreciated.