Put Options on Employer Stock Do Not Make For Cash Distributions
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Source: Volume 22, Number 04, March/April 2009 , pp.62-64(3)
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Abstract:
The issue in TAM 200841042 1 on which LMSB requested technical advice was whether stock distributions from the employer’s plan should be treated as cash distributions when participants exercise put options at the time of distribution and sell their shares back to the employer. The Service concluded that such distributions should not be treated as cash distributions.Keywords: Section 4975(e)(7); Regulation 54.4975-7(b)(10)
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