ABATax Comment Concerning IRS Notice 2001-10

Section of Taxation
Submission to the Federal Executive Branch

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Comments Concerning IRS Notice 2001–10
April 2001

I.  Characterizing Equity SDAs

  1. Section 7872
     
    1. Calculating the Period for a Term Loan

      Assuming that the arrangement described in Part 2 above is a "term loan" for purposes of Section 7872, it is unclear how to calculate the length of its term. What actuarial tables can be used for the calculation? Can the tables be adjusted for the employee's actual health status? Can the employer take into account the possibility that the employee might terminate employment prior to her date of death when determining the period for the term loan?

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