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Transfer from 501(c)(9) to another 501(c)(9)


benpat3
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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

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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

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  • 3 months later...
Guest L337pwner5

PLR200211053 is one relevent PLR. There are plenty more out there, but I just happened to be looking at this one last week.

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