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PART I — INCOME TAXES›Article 14 of the Treaty provides:

SECTION 3. SCOPE

Internal Revenue Bulletin 2004-7 · 2026-10-03 edition · updated 2026-10-04 · United States

This revenue procedure sets forth certain requirements related to an ESOP’s distribution of S corporation stock to a participant where the participant elects to have the S corporation stock distributed to an IRA in a direct rollover. If these requirements are satisfied, the Service will accept the position that the distribution does not affect the S corporation’s election to be taxed as an S corporation.

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▸Contents — Internal Revenue Bulletin 2004-7
Internal Revenue Bulletin 2004-7

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