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| In Rev. Rul. 2003-6, IRS Clarifies Application of EGTRRA S Corp ESOP Provision's Effective Date Internal Revenue Service [IRS]  [Official Guidance] Dec. 18, 2002 Excerpt: An S corporation ESOP described in this ruling is not eligible for the delayed effective date under § 409(p) of the Code provided under section 656(d)(2) of EGTRRA, and thus is subject to the nonallocation rules of § 409(p) of the Code effective for plan years ending after March 14, 2001. Any taxpayer who is a disqualified person with respect to the S corporation ESOP is treated as receiving a deemed distribution [and] excise taxes under § 4979A apply ... |
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