Milo G. and Sarah E. Chapman, et al. - Page 13

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            plan loans does not exceed the lesser of:  (i) $50,000, or (ii)                              
            the greater of $10,000 or half of the participant's vested                                   
            accrued benefit under the plan; and (2) the loan, by its terms,                              
            requires repayment within 5 years.  Sec. 72(p)(2)(A) and (B).                                
                  Section 72(p)(2)(C) was added by the Tax Reform Act of 1986,                           
            Pub. L. 99-514, sec. 1134(b), 100 Stat. 2085, 2484, and limits                               
            the exception in section 72(p)(2) to those loans that are                                    
            required to be amortized in substantially level installments paid                            
            at least quarterly.  This provision applies to loans made,                                   
            renewed, renegotiated, modified, or extended after December 31,                              
            1986.  Id.        Section 72(t)(1) imposes an additional tax on an                           
            amount received from a qualified retirement plan equal to 10                                 
            percent of the portion of such amount that is includable in gross                            
            income.  Section 72(t)(2) exempts distributions from the                                     
            additional tax if the distributions are made, inter alia:  (1) To                            
            an employee age 59� or older; (2) to a beneficiary (or the estate                            
            of the employee) on or after the death of the employee; (3) on                               
            account of disability; (4) as part of a series of substantially                              
            equal periodic payments made for life; (5) to an employee after                              
            separation from service after attainment of age 55; or (6) as                                
            dividends paid with respect to corporate stock described in                                  
            section 404(k).                                                                              









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