Details of Public Law 117-328, section 114 , Deferral of Tax for Certain Sales of Employer Stock to Employee Stock Ownership Plan Sponsored by S Corporation

The provision adds an additional limitation to the non-recognition treatment under IRC section 1042. This provision allows no more than 10 percent of the amount realized on certain sales of S-Corporation stock to a S-Corporation employee stock ownership plan (ESOP) to be eligible for non-recognition treatment.

The provision also modifies the term “domestic C corporation” to “domestic corporation”.

23/24 24/25 25/26 26/27 27/28 N/A N/A N/A ($1,000,000) ($5,600,000)