Example.
Deemed-owned ESOP shares mean, with respect to any person-
1 Shareholders | 2 Deemed-owned ESOP shares (total of 1,000) | 3 Percentage deemed-owned ESOP shares | 4 Disqualified person |
B | 330 | 33 | Yes. |
C | 145 | 14.5 | Yes. |
D | 75 | 7.5 | No. |
E | 30 | 3 | No. |
F | 20 | 2 | No. |
Other participants | 400 (none exceed 10 shares) | 1 or less | No. |
1 Shareholders | 2 Deemed-owned ESOP shares (total of 1,000) | 3 Percentage deemed-owned ESOP shares | 4 Options (240) | 5 Shareholder percentage of deemed-owned ESOP plus synthetic equity shares | 6 Disqualified person |
B | 330 | 33 | Yes (col. 3). | ||
C | 145 | 14.5 | Yes (col. 3). | ||
D | 75 | 7.5 | No. | ||
E | 30 | 3 | 110 | 11.1% ([30 + 91.7] divided by 1,091.7) | Yes (col. 5). |
F | 20 | 2 | 130 | 11.6% ([20 + 108.3] divided by 1,108.3) | Yes (col. 5). |
Other participants | 400 (none exceeds 10 shares) | 1 or less | No. |
1 Determination date | 2 Present value of nonqualified deferred compenstion on determination date | 3 Share value on determination date | 4 New shares of synthetic equity on determination date | 5 Aggregate number of synthetic equity shares on determination date |
January 1, 2005 | A grant is made on January 1, 2005 with a present value of $1,000. An additional grant of nonqualified deferred compensation with a present value of $775 is made on March 1, 2005 | $10 per share | 100 | 100 |
January 1, 2006 | An additional grant is made on December 31, 2005 which has a present value of $800 on January 1, 2006. The March 1, 2005 grant has a present value on January 1, 2006 of $800 | $8 per share | 200 | 300 |
January 1, 2007 | No new grants made | $12 per share | 300 | |
January 1, 2008 | An additional grant is made on December 31, 2007 which has a present value of $3,000 on January 1, 2008. The grants made during 2005 through 2007 have an aggregate present value on January 1, 2008 of $3,750 | $15 per share | 200 | 450 |
January 1, 2009 | No new grants are made | $11 per share | 450 | |
January 1, 2010 | No new grants are made | $22 per share | 450 | |
January 1, 2011 | No new grants are made. The grants made during 2005 through 2008 have an aggregate present value on January 1, 2011 of $7,600 | $20 per share | 380 |
26 C.F.R. §1.409(p)-1T