 | United States. Internal Revenue Service - 1972 - 624 lapas
...in the regulations promulgated thereunder against a trust borrowing funds to purchase investments. The borrowing of funds by a trust and investing them...unable to borrow money from usual financial sources. However, a qualified employees' trust is subject to tax on unrelated business taxable income under... | |
 | United States. Congress. Joint Economic Committee - 1976 - 1120 lapas
...situation wherein the borrowing of funds by the trust has either the purpose or effect of furnishing capital or property for use in the employer's business...when the employer's financial condition is such that is is unable to borrow noney from usual financial sources. Clearly the Employee Stock Ownership Trust... | |
 | United States. Congress. Senate. Select Committee on Small Business - 1979 - 696 lapas
...employer as. for example, borrowing in order to furnish capital or property for use in the employers business at a time when the employer's financial condition...shareholder of a closely-held company. The benefit of such a transaction to plan participants will probably be closely scrutinized by the IRS Accurate valuation... | |
 | United States. Congress. Senate. Select Committee on Small Business - 1979 - 1636 lapas
...purpose of benefiting the employer, as, for example, borrowing in order to furnish capital on pro|>erty for use in the employer's business at a time when...unable to borrow money from usual financial sources." This can be interpreted as disqualifying a plan where tlic trust is used to obtain financing that would... | |
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... the employer or an entity closely related to the employer do not disqualify a trust as one for the exclusive benefit of employees unless the borrowing is undertaken for the purpose of benefiting the employer as. for example, borrowing in order to... 