Guest Buzzman Posted October 14, 2008 Share Posted October 14, 2008 Employer X is an S corporation that had a nonqualified deferred compensation plan. In anticipation of the sale of all the stock of X (in which a Section 338(h)(10) election will be made) and the treatment of the deferred compensation plan as an excluded liability by purchaser Y, a C corporation, X terminated and paid out the plan in January 2008. The stock sale occurred March 31, 2008. With the deferred comp being paid out in the short S year of X (January 1 to March 30, 2008), is there any way under Section 404(a)(5) and Reg. 1.404(a)-12(b)(1) (or other guidance) that X should be able to take the deduction for the contributions attributable to the payout in its short S year? Any thoughts are appreciated. Link to comment Share on other sites More sharing options...
bdeancpa Posted July 30, 2015 Share Posted July 30, 2015 Your question was asked in 2008 and I see no response, but I have the same question today. Did you ever figure out the appropriate answer? Thanks. Dean Huber Link to comment Share on other sites More sharing options...
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