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Tax Deduction for ESOP Was Twice As Nice in IRS Private Letter Ruling
The Retirement Plan Blog 
Sept. 18, 2007
Excerpt: Conventional wisdom says that a plan sponsor cannot generally deduct more that 25% of eligible compensation to a qualified retirement plan. But 'generally' means in ERISA terms that there are exceptions. And here's a very interesting one. A C corporation - let's call it 'C' for short - that sponsored an ESOP wanted to deduct more than 25% of compensation. In fact, it wanted to make three types of contribution.
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