Plan loan note can be transferred as part of a direct rollover without adverse tax consequences to plan participants
Article Abstract:
The IRS stated in Private Letter Ruling 9617046 that transfer of a plan loan as part of a direct rollover pursuant to an employee transfer to a related company does not result in the loan being treated as renegotiated, extended, revised or renewed. Under the Tax Reform Act of 1986, additional requirements apply to plan loans if a renewal, extension, renegotiation or revision occurs after 1986. The IRS found that the terms and conditions of the loan did not change pursuant to the loans, so the additional requirements did not apply.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1996
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Treasury outlines priorities for 1995
Article Abstract:
The US Department of the Treasury intends provide guidance and regulations on a number of employee benefits topics, focusing on retirement plans, executive compensation, the Retirement Protection Act of 1994 and employment taxes. Guidance is expected on employment tax issues including taxation of nonqualified plans and withholding taxes. Retirement Protection Act issues include mortality assumptions, funding and cash-out requirements. Benefits activities will include updating of several Revenue Procedures.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1995
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