benpat3 Posted November 26, 2007 Share Posted November 26, 2007 Can a 501©(9) transfer transfer assets to another 501©(9) trust? For instance, can a SUB Fund transfer assets to an HRA account or a H/W Plan? I have looked at GCM 39052 which seems to state that this can be done and does not violate the inurement rules. If my conclusion is incorrect or if you know of any other sources for this question, please let me know. Benjamin Smith Senior Manager - Indirect Tax Ernst & Young 317.681.7495 Benjamin.Smith@ey.com Link to comment Share on other sites More sharing options...
benpat3 Posted November 27, 2007 Author Share Posted November 27, 2007 Can a 501©(9) transfer transfer assets to another 501©(9) trust? For instance, can a SUB Fund transfer assets to an HRA account or a H/W Plan?I have looked at GCM 39052 which seems to state that this can be done and does not violate the inurement rules. If my conclusion is incorrect or if you know of any other sources for this question, please let me know. A secondary question is whether this transfer from one VEBA to another VEBA is a taxable event? Benjamin Smith Senior Manager - Indirect Tax Ernst & Young 317.681.7495 Benjamin.Smith@ey.com Link to comment Share on other sites More sharing options...
vebaguru Posted November 29, 2007 Share Posted November 29, 2007 There are PLRs on point for both of these issues. Link to comment Share on other sites More sharing options...
Guest L337pwner5 Posted March 6, 2008 Share Posted March 6, 2008 PLR200211053 is one relevent PLR. There are plenty more out there, but I just happened to be looking at this one last week. Link to comment Share on other sites More sharing options...
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