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Showing results for tags 'attribution'.
Found 4 results
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Hi folks! Scenario: Parent owns 100% of Company A. Parent/Adult Child are 50/50 partners in Company B. Unrelated entities. Am I correct in that there is no controlled group here? It is my understanding that ownership is only attributed from/to Parent/Adult Child if they own over 50%, not 50% exactly. Or am I not reading the rules correctly? Thank you! Donnie
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Attribution from a Trust to its beneficiaries
401_noob posted a topic in Retirement Plans in General
Greetings friends! I have a question regarding the attribution from a grantor trust to the beneficiaries of the Trust. The EOB says that if a trust has an ownership interest in another organization, that interest is attributed to the beneficiaries in the trust who have a 5% or more actuarial interest in the trust, in proportion to each beneficiary's actuarial interest. What is actuarial interest and how is it determined? I found in S. Derrin Watson's Who's the Employer Q&A column, question 167- https://benefitslink.com/cgi-bin/qa.cgi?db=qa_who_is_employer&n=167, that it is determined according to IRS actuarial tables, but what table and how? Any help would be appreciated!! Thanks in advance! -
Hi - I am seeking practical feedback on the question of attribution of ownership to minor children. I don't question that IRC section 1563 attributes ownership from parents to children under 21. This creates controlled groups of entirely separate companies simply because they are owned by spouses with minor children. The thing I struggle with are the many cases where the issue goes unnoticed (or is even ignored). I have lost a couple of prospects because they refuse to believe that aggregation is mandatory. For those with existing plans, they often say their TPA never notified them (even in cases where they are confident the TPA is aware of the facts.) I am curious about others' experience. Do you find this rule is often overlooked? I've never heard of IRS making an issue of it. Have you?
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Do the family attribution rules (for controlled group purposes) apply between a family member residing outisde the United States who is not an American citizen and a family member residing in the United States?
