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Text of IRS PLR 201424030: Contribution of S Corporation Distributions to ESOP Did Not Constitute Annual Additional Under Section 415 (PDF)
Internal Revenue Service [IRS] Link to more items from this source
[Official Guidance]
June 14, 2014
Dated March 20, 2014; published online June 13, 2014. Excerpt: "[T]he Taxpayer proposes to make S corporation distributions ... of $Z to the Plan, ... The distribution would be allocated to the participants of the Plan based on the number of shares of Taxpayer stock allocated to each participant on the record date for the distribution.... The facts and circumstances of the present case do not support the recharacterization of these S corporation distributions as annual additions under the authority of section 1 .415(c)-1 (b)(4) of the regulations. Instead these amounts constitute distributions of earnings to the Taxpayer's shareholders and not contributions or other additions with respect to participants of the ESOP."

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