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Importance of Corporate Structure for Employee Stock Ownership Plans
RSM US Link to more items from this source
July 17, 2018

"The parent company sought a ruling that its stock held by the ESOP will constitute qualifying employer securities with respect to the subsidiary, and that the application of sections 409(h), 409(p), 512(e)(3) and 4975(e)(7) would not be affected by the C corporation subsidiary's adoption of the plan.... Ultimately, the IRS concluded [in PLR 201828007] that the C corporation's adoption of its parent company's ESOP will not affect its status and the rules will continue to apply based upon the S corporation parent, as the ESOP held employer securities consisting of stock in an S corporation."

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