Congress frequently uses disqualified person criteria benchmarks in effecting policy bright lines. The Section 409(p) S-Corporation ESOP disqualified person criterion proves no exception to this legislative practice. Historically, commentators have underscored the anti-abuse consequences deriving the provision's 2001 enactment.
To date, no one has pointed to the economic reality that Section 409(p)'s disqualified person criterion effects Congressional policy favoring economically substantive succession planning as a means for sustaining contributions to America's productivity beyond the limits of the entrepreneur's semi-retirement, complete retirement, and physical life. The article on which this webcast is based fills that void.
The Succession Planning Progressive Quaternary Order Hierarchy
Section 409(p) Diversification
Section 409(p) Implications for the Succession Planning Quaternary Hierarchy
**Please Note: If you need credit reported to the IRS for this IRS approved program, please download the IRS CE request form on the Course Materials Tab and submit to [email protected].
Delivery Method: Individual webcast
CPE Credit: Taxes
Program Level: Intermediate