Revenue Ruling 2004-4 Provides Guidelines to Classify Certain SESOP Transactions as 'Listed Tax Shelters'

BVResearch Pro
Willamette Insights
February 1, 2005
Craig A. Jacobson, MBA

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Summary

In recently issued Revenue Ruling 2004-4, IRB 2004-6, 414, the Internal Revenue Service (ôServiceö) addresses S corporation ESOP provisions that attempt to circumvent Internal Revenue Code Section 409(p). According to the Service, these provi-sions at ...
Revenue Ruling 2004-4 Provides Guidelines to Classify Certain SESOP Transactions as 'Listed Tax Shelters'
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