A rabbi trust is a trust established by an employer to provide
a source of funds which
may be used to satisfy the employer's obligation to executives under
a non-qualified
executive benefit plan. The trust is referred to as a rabbi trust
because the first IRS
letter ruling with respect to this type of trust involved a rabbi
whose congregation had made contributions to such a trust for his
benefit. The ruling stated that the rabbi
would not be taxed on the funds in the trust until the funds were
actually distributed
to the rabbi or his beneficiary upon his death, disability, retirement
or termination of
employment.
Typically, the rabbi trust is established as an irrevocable trust.
The employer must
Give up all rights to the assets in the trust and may not terminate
the trust. The trust
is also usually considered a grantor trust, with income being taxed
to the grantor,
usually the employer.
The primary purpose of the rabbi trust is to offer some limited
level of security to
the employee with respect to their nonqualified benefits. This is
especially true for
a Nonqualified Deferred Compensation Plan (NQDC) where the employee
defers compensation with only the contractual promise of the employer
to pay the benefits. Employee deferrals may be placed in the rabbi
trust as deferrals are made. If a rabbi trust is "locked",
funds placed in the trust may not revert back to the employer until
all
benefit obligations have been satisfied.
How much security is really provided? A key important feature of
any rabbi trust
is that the assets in the trust must be subject to the claims of
the employer's creditors at all times. If the employer becomes insolvent,
all trust assets become available to the employer's creditors, including
the NQDC participants. In other words, if insolvency or bankruptcy
occurs, the NQDC participants stand in line with other
employer unsecured creditors. The security offered by the rabbi
trust is for
" Change of mind: The employer may not access the assets in
the trust once
they have been contributed. " Change in control: A friendly
or unfriendly takeover will not affect the assets in the trust.
Some rabbi trusts have a trigger that
requires full funding of designated benefits upon a change in control.
This is addressed in the plan document
IRS Positions on Rabbi Trusts
The IRS has ruled that the establishment of a rabbi trust would
not in itself cause a
nonqualified plan to be considered funded for tax purposes since
the assets are subject
to the claims of creditors, and are not set aside solely for the
benefit of participants.
In Rev. Proc. 92-64, the IRS stated specific criteria that are necessary
to obtain a
Favorable ruling on a rabbi trust used in connection with nonqualified
plans. The Revenue Procedure contains a model rabbi trust that is
intended to serve as a safe
Harbor for taxpayers who adopt and maintain the model trust in connection
with nonqualified plans.
Rabbi Trusts and ERISA
The Department of Labor (DOL) has ruled that the establishment
of a rabbi trust
will not in itself cause a nonqualified plan to be considered funded
for ERISA
purposes. Not would the transfer of assets cause the plan to be
considered funded.
The consequences of a plan being considered funded for ERISA purposes
are that the plan would have to satisfy all the requirements of
Title 1 of ERISA with cover participation, vesting, funding, fiduciary
and enforcement requirements.
Taxation of Rabbi Trusts
A rabbi trust is considered a grantor trust for income tax purposes.
Any trust income
is taxed to the employer who established the trust. Contributions
to the trust are not
income tax deductible by the employer. However, the employer may
deduct the full
amount of the benefit payment as the trust makes payments to the
plan participants.
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