Tax Court holds Prime Plan is a welfare plan but not a 10-or-more employer plan
Article Abstract:
A 1997 Tax Court decision held the Prime Plan concept, generally marketed to owners of closely held corporations, was not a 10-or-more employer plan, but should be considered a welfare benefit plan. The IRS had contended the plan was a deferred compensation arrangement, although it persuaded the Court regarding the limited applicability of the 10-or-more employer plan exception. The Tax Court found Prime Plan to be a aggregated group of separate welfare benefit plans.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1997
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Proposed examination guidelines under sections 404 and 412
Article Abstract:
Employee benefit plan administrators may gain valuable nonbinding information on the IRS's approach during examinations to IRC section 412 regarding minimum funding standards and to section 404 deductions by reviewing employee guidelines. The guidelines which were publically released in Dec 1997 are intended to provide IRS examiners with guidance on important issues that should or may arise during examinations. Detailed treatment of the issues is provided.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1998
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