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IRS Provides Reminder That Employers May Not Currently Deduct Contributions of Their Own Debt Securities
Groom Law Group Link to more items from this source
[Guidance Overview]
Sept. 6, 2019

"The 2018 tax filing deadline for employer 'grace period' contributions to their pension plans is coming up on Friday, September 13, 2019.... [IRS Chief Counsel Memo 201935011] explains: [1] An employer's contribution of its own promissory note is not deductible as an actual payment 'regardless of whether the note is secured or transferable.' [2] This same 'no-deduction' principle applies if the employer's debt is publicly traded or if the debt is issued by a member of the plan sponsor's 'controlled group.' "

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