Business Expenses: Reportable Transactions .com: 419 Plan, 412i Plan

Business Expenses: Reportable Transactions .com: 419 Plan, 412i Plan

2 comments:


  1. Section 404.--Deduction for Contributions of an Employer to an Employees’ Trust or
    Annuity Plan and Compensation Under a Deferred Payment Plan
    (Also, §§ 401, 412, 6011, 6111, 6112; §§ 26 CFR 1.401-1, 1.412(i)-1, 1.6011-4,
    301.6111-2, 301.6112-1.)
    Rev. Rul. 2004-20
    ISSUES
    Issue 1: Can a qualified pension plan be a plan described in § 412(i) of the Internal
    Revenue Code if the plan holds life insurance contracts and annuity contracts for the
    benefit of a participant that provide for benefits at normal retirement age in excess of the
    participant’s benefits at normal retirement age under the terms of the plan?
    Issue 2: If a qualified pension plan holds life insurance contracts providing for life
    insurance on a participant’s life in excess of the participant’s death benefit under the
    terms of the plan, are contributions for premiums for such excess life insurance
    coverage currently deductible by the employer?
    FACTS
    Situation 1
    Employer M maintains Plan A, a defined benefit plan that is funded solely by life
    insurance contracts and annuities with level annual premiums for each participant
    commencing with the date the individual becomes a participant in the plan (or, in the
    case of an increase in benefits, commencing at the time the increase becomes
    effective) and ending with the individual’s attainment of normal retirement age. Plan A
    is intended to be a plan described in § 412(i). The amounts that will be accumulated
    under the insurance contracts and annuity contracts for the benefit of a participant at
    normal retirement age, assuming premiums are paid and

    ReplyDelete

  2. Section 404.--Deduction for Contributions of an Employer to an Employees’ Trust or
    Annuity Plan and Compensation Under a Deferred Payment Plan
    (Also, §§ 401, 412, 6011, 6111, 6112; §§ 26 CFR 1.401-1, 1.412(i)-1, 1.6011-4,
    301.6111-2, 301.6112-1.)
    Rev. Rul. 2004-20
    ISSUES
    Issue 1: Can a qualified pension plan be a plan described in § 412(i) of the Internal
    Revenue Code if the plan holds life insurance contracts and annuity contracts for the
    benefit of a participant that provide for benefits at normal retirement age in excess of the
    participant’s benefits at normal retirement age under the terms of the plan?
    Issue 2: If a qualified pension plan holds life insurance contracts providing for life
    insurance on a participant’s life in excess of the participant’s death benefit under the
    terms of the plan, are contributions for premiums for such excess life insurance
    coverage currently deductible by the employer?
    FACTS
    Situation 1
    Employer M maintains Plan A, a defined benefit plan that is funded solely by life
    insurance contracts and annuities with level annual premiums for each participant
    commencing with the date the individual becomes a participant in the plan (or, in the
    case of an increase in benefits, commencing at the time the increase becomes
    effective) and ending with the individual’s attainment of normal retirement age. Plan A
    is intended to be a plan described in § 412(i). The amounts that will be accumulated
    under the insurance contracts and annuity contracts for the benefit of a participant at
    normal retirement age, assuming premiums are paid and

    ReplyDelete