Trust may split two inherited IRAs among three children without current tax

Plain-English summary

A decedent died after his required beginning date, leaving his own IRA and an IRA he had inherited from an older sibling to a revocable trust that became irrevocable at death. The trust divided its residue among separate trusts for the decedent's three children and satisfied the requirements to be treated as a see-through trust. For the decedent's own IRA, all three children were treated as designated beneficiaries, but the oldest child's life expectancy controlled the required distribution period because trust beneficiaries could not use separate accounts to set different life expectancies. The trustees could nevertheless divide that IRA into three separately maintained inherited IRAs through trustee-to-trustee transfers without taxable distributions or rollovers. The sibling's IRA had to continue using the decedent's remaining life expectancy, and it too could be divided into three separately maintained inherited IRAs without current tax. The pre-SECURE Act required-minimum-distribution rules applied because the decedent died before the amendments took effect.

Ruling snapshot

• Question: How may a see-through trust divide the decedent's own IRA and a second-generation inherited IRA among three children, and which life expectancies govern?
• Outcome: Approved, both IRAs may be split tax-free, with the oldest child governing the first IRA and the decedent's remaining life expectancy governing the second
• Key authorities: IRC §§ 401(a)(9) and 408(a)(6), (d); Treas. Reg. §§ 1.401(a)(9)-4, -5, -8 and 1.408-8; Rev. Rul. 78-406

Full text (IRS public release)

 Internal Revenue Service                                       Department of the Treasury
                                                                Washington, DC 20224

 Number: 202140011                                              Third Party Communication: None
 Release Date: 10/8/2021                                        Date of Communication: Not Applicable
 Index Number: 401.06-00, 401.06-01,
               401.06-02, 408.00-00,                            Person To Contact:
               408.08-00                                        --------------------, ID No. -----------------
                                                                Telephone Number:
 --------------------------------                               -------------------
 ------------------------------------------------------------   Refer Reply To:
 -------                                                        CC:EEE:EB:QP1
 -----------------------------------------------                PLR-104779-21
 ----------------------------------                             Date: July 12, 2021




Legend:

 Decedent A          = ---------------------------
 Decedent B          = -------------------------
 Trust T             = ---------------------------------------------------------------------------------------------
                       ---------------------------------------------------------------------------------------------
                       --------------
 Child C             = ---------------------------
 Child D             = -----------------------------
 Child E             = --------------------------
 State S             = -------------
 IRA X               = ---------------------------------------------------------------------------------------------
                       ---------------------------------------------------------------------------------------------
                       ---------------------------------------------------------------------------------------------
                       -----------------------------------------------------------------------------
 IRA Y               = ---------------------------------------------------------------------------------------------
                       ---------------------------------------------------------------------------------------------
                       ---------------------------------------------------------------------------------------------
                       -------------------------------------------------------------------------
 Date 1              = -------------------
 Date 2              = ----------------------
 Date 3              = ---------------------
 Year 1              = -------
 Year 2              = -------

Dear ----------------:

This is in response to a request for a letter ruling under sections 401(a)(9) and 408 of
the Internal Revenue Code (Code), submitted on behalf of Trust T by its authorized
PLR-104779-21                                 2

representatives in correspondence dated January 15, 2021, as updated by
correspondence dated May 7, 2021.

The following facts and representations have been submitted under penalties of perjury
in support of the rulings requested.

Decedent A died on Date 3 in Year 1 after his “required beginning date,” as that term is
defined in section 401(a)(9)(C). Decedent A was survived by three children, Child C,
Child D, Child E, all of whom were alive as of the date of this ruling request.

Prior to his death, Decedent A established Trust T, which has not been amended,
revoked or otherwise changed since the date of his death. The terms of Trust T provide
that Trust T was revocable by Decedent A before his death, but irrevocable upon his
death. Trust T is subject to, and is valid under, the laws of State S.

Decedent A was the owner of IRA X, an individual retirement arrangement (IRA). At the
time of his death, Decedent A was the beneficiary of IRA Y, which he had previously
inherited from Decedent B, his older sibling, upon Decedent B’s death. Trust T was
named the beneficiary of IRA X and IRA Y by means of beneficiary designations made
before Decedent A’s death. The beneficiary designations were made on Date 2 for IRA
X and Date 1 for IRA Y. You have represented that at all relevant times IRA X and IRA
Y have been maintained in accordance with section 408 and all applicable tax rules.

On October 31 of Year 2 (the calendar year immediately following Year 1), IRA X’s
custodian was provided with information concerning the terms of Trust T and the
identities of its beneficiaries.

The terms of Trust T provide that at the death of Decedent A, the residual balance of
the trust property is to be divided into separate trusts for each of Decedent A’s
descendants, per stirpes. Trust T identifies Decedent A’s three children as trust
beneficiaries. The residual balance of trust property includes the assets of IRA X and
IRA Y.

The trustees of Trust T propose to separate the assets of IRA X by means of trustee-to-
trustee transfers to three distinct IRAs, each for the separate benefit of one of Decedent
A’s three children. Each transferee IRA will be maintained in the name of Decedent A
(deceased) for the benefit of the child beneficiary, as beneficiary of Trust T. For
example, one transferee IRA will be maintained in the name of Decedent A (deceased)
for the benefit of Child C, as beneficiary of Trust T. Distributions from each of these
transferee IRAs will be made over the life expectancy of Child C, the eldest of Decedent
A’s three children.

In addition, the trustees of Trust T propose to separate the assets of IRA Y by means of
trustee-to-trustee transfers to three distinct IRAs, each for the separate benefit of one of
Decedent A’s three children. Each transferee IRA will be maintained in the name of
PLR-104779-21                                 3

Decedent B (deceased) for the benefit of the child beneficiary, as beneficiary of
Decedent A. For example, one transferee IRA will be maintained in the name of
Decedent B (deceased) for the benefit of Child C, as beneficiary of Decedent A.
Distributions from each of these transferee IRAs will be based on the remaining life
expectancy of Decedent A. You have represented that under the ownership of each
child beneficiary the beneficiary’s transferee IRA derived from IRA X will not be
combined with the beneficiary’s transferee IRA derived from IRA Y. Having different
distribution periods, the two transferee IRAs for the benefit of each child beneficiary will
remain as separate accounts until each account is fully distributed.

Based on the facts and representations, the following rulings were requested:

1. Each child beneficiary of Trust T is treated as having been designated as a
beneficiary of IRA X in accordance with § 1.401(a)(9)-4, Q&A-5, for purposes of
determining the distribution period under section 401(a)(9). Required minimum
distributions from IRA X are calculated using the life expectancy of Child C, the oldest
child beneficiary.

2. The trustees of Trust T may transfer the assets of IRA X by means of trustee-to-
trustee transfers to IRAs titled IRA of “Trust T fbo (name of child beneficiary), as
beneficiary of Trust T” in order to separate the interest of each child beneficiary in the
assets of IRA X, without such transfers constituting taxable distributions under section
408(d)(1) or rollovers under section 408(d)(3).

3. Required minimum distributions from IRA Y are calculated using the life expectancy
of Decedent A.

4. The trustees of Trust T may transfer the assets of IRA Y by means of trustee-to-
trustee transfers to IRAs titled IRA of “Decedent B fbo (name of child beneficiary), as
beneficiary of Decedent A” in order to separate the interest of each child beneficiary in
the assets of IRA Y, without such transfers constituting taxable distributions under
section 408(d)(1) or rollovers under section 408(d)(3).

Law

Under section 401(a)(9)(A), a trust will not be considered qualified unless the plan
provides that the entire interest of each employee (1) will be distributed to such
employee not later than the required beginning date, or (2) will be distributed, beginning
no later than the required beginning date, over the life of such employee or over the
lives of such employee and a designated beneficiary or over a period not extending
beyond the life expectancy of such employee or the life expectancy of such employee
and a designated beneficiary.

Section 401(a)(9)(B)(i) provides that a trust shall not constitute a qualified trust under
the Code unless the plan provides that if the distribution of the employee’s interest has
PLR-104779-21                                        4

begun in accordance with section 401(a)(9)(A)(ii), and the employee dies before his
entire interest has been distributed to him, the remaining portion will be distributed at
least as rapidly as under the method being used under section 401(a)(9)(A)(ii) as of the
date of death.

Section 401(a)(9)(C) provides, in relevant part, that the term “required beginning date”
means April 1 of the calendar year following the calendar year in which the employee
attains age 70 ½.1

Section 401(a)(9)(E) provides that “designated beneficiary” means any individual
designated as a beneficiary by the employee.

Section 1.401(a)(9)-4, Q&A-1, provides, in relevant part, that a designated beneficiary is
an individual who is designated as a beneficiary under the plan. An individual may be
designated as a beneficiary under the plan either by the terms of the plan or, if the plan
so provides, by an affirmative election by the employee (or the employee’s surviving
spouse) specifying the beneficiary. A designated beneficiary need not be specified by
name in the plan in order to be a designated beneficiary so long as the individual who is
to be the beneficiary is identifiable under the plan. The member of a class of
beneficiaries capable of contraction or expansion will be treated as being identifiable if it
is possible to identify the class member with the shortest life expectancy.

Section 1.401(a)(9)-4, Q&A-3, provides that only individuals may be designated
beneficiaries for purposes of section 401(a)(9). A person who is not an individual, such
as the employee’s estate or a charitable organization, may not be a designated
beneficiary. If a person other than an individual is designated as a beneficiary of an
employee’s benefit, the employee will be treated as having no designated beneficiary
for purposes of section 401(a)(9), even if there are also individuals designated as
beneficiaries.

Section 1.401(a)(9)-4, Q&A-4, provides in relevant part, that in order to be a designated
beneficiary, an individual must be a beneficiary as of the date of the employee’s death.
Generally, an employee’s designated beneficiary will be determined based on the
beneficiaries designated as of the date of death who remain beneficiaries as of
September 30 of the calendar year following the calendar year of the date of death.

Section 1.401(a)(9)-4, Q&A-5, provides that where a trust is named as a beneficiary of
an employee, the trust is not a designated beneficiary; however, beneficiaries of the
trust with respect to the trust’s interest in the employee’s benefit will be treated as
having been designated as beneficiaries for purposes of determining the distribution
period under section 401(a)(9) if the following requirements are met: (1) the trust is valid
under state law, or would be but for the fact there is no corpus; (2) the trust is

1 Section 114 of the SECURE Act amended section 401(a)(9)(C) to provide that, for individuals who had

not attained 70 ½ prior to January 1, 2020, the term “required beginning date” means April 1 of the
calendar year following the calendar year in which the employee attains age 72.
PLR-104779-21                                 5

irrevocable or will, by its terms, become irrevocable upon the death of the employee; (3)
the beneficiaries of the trust who are beneficiaries with respect to the trust’s interest in
the employee’s benefit are identifiable within the meaning of § 1.401(a)(9)-4, Q&A-1,
from the trust instrument; and (4) relevant documentation has been timely provided to
the plan administrator.

Section 1.401(a)(9)-4, Q&A-5(c), provides that, in the case of a trust having more than
one individual beneficiary, § 1.401(a)(9)-5, Q&A-7, applies in determining the
designated beneficiary whose life expectancy will be used to determine the distribution
period. The subsection further provides that the separate account rules under
§ 1.401(a)(9)-8, Q&A-2, are not available to the beneficiaries of a trust with respect to
the trust’s interest in the employee’s benefit.

Section 1.401(a)(9)-4, Q&A-6(b), provides, in relevant part, with respect to required
minimum distributions after the death of an employee, that documentation sufficient to
enable the plan administrator to identify beneficiaries of the plan must be provided by
the trustee of the trust to the plan administrator by October 31 of the calendar year
immediately following the calendar year in which the employee died.

Section 1.401(a)(9)-5, Q&A-5(a), provides that if an employee dies on or after the
employee’s required beginning date and has a designated beneficiary, the applicable
distribution period for minimum distributions for distribution calendar years after the
distribution calendar year containing the employee’s date of death is the greater of the
life expectancy (determined in accordance with § 1.401(a)(9)-5, Q&A-5(c)) of the
designated beneficiary or the employee.

Section 1.401(a)(9)-5, Q&A-5(c)(1), provides that, with respect to minimum distributions
in any case in which the surviving spouse is not the sole beneficiary, the applicable
distribution period measured by the beneficiary’s remaining life expectancy is
determined using the beneficiary’s age as of the beneficiary’s birthday in the calendar
year immediately following the calendar year of the employee’s death. In subsequent
calendar years, the applicable distribution period is reduced by one for each calendar
year that has elapsed after the calendar year immediately following the calendar year of
the employee’s death.

Section 1.401(a)(9)-5, Q&A-7, provides, in general, that if more than one beneficiary is
designated as a beneficiary with respect to an employee as of the applicable date for
determining the designated beneficiary under A-4 of § 1.401(a)(9)-4, the designated
beneficiary with the shortest life expectancy will be the designated beneficiary for
purposes of determining the applicable distribution period.

Section 1.401(a)(9)-8, Q&A-2(a)(1), provides that, except as otherwise provided in
Q&A-2, if an employee’s benefit under a defined contribution plan is divided into
separate accounts under the plan, the separate accounts will be aggregated for
purposes of satisfying the rules in section 401(a)(9).
PLR-104779-21                                6


Section 1.401(a)(9)-8, Q&A-2(a)(2), provides that, if the employee’s benefit in a defined
contribution plan is divided into separate accounts and the beneficiaries with respect to
one separate account differ from the beneficiaries with respect to the other separate
accounts of the employee under the plan, for years subsequent to the calendar year
containing the date as of which the separate accounts were established, or date of
death if later, such separate account under the plan is not aggregated with the other
separate accounts under the plan in order to determine whether the distributions from
such separate account under the plan satisfy section 401(a)(9). Instead, the rules in
section 401(a)(9) separately apply to such separate account under the plan. However,
the applicable distribution period for such separate account is determined disregarding
the other beneficiaries of the employee’s benefit only if the separate account is
established on a date no later than the last day of the year following the calendar year
of the employee’s death.

Section 1.401(a)(9)-8, Q&A-3, provides that, for purposes of section 401(a)(9), separate
accounts in an employee’s account are separate portions of an employee’s benefit
reflecting the separate interests of the employee’s beneficiaries under the plan as of the
date of the employee’s death for which separate accounting is maintained. The
separate accounting must allocate all post-death investment gains and losses,
contributions, and forfeitures, for the period prior to the establishment of the separate
accounts, on a pro-rata basis in a consistent and reasonable manner among the
separate accounts.

Section 408(a)(6) provides that, under regulations prescribed by the Secretary, rules
similar to the rules of section 401(a)(9) shall apply to the distribution of the entire
interest of an individual for whose benefit an IRA is maintained.

Section 408(d)(1) provides, generally, that in accordance with the rules of section 72,
amounts paid or distributed from an IRA are included in gross income by the payee or
distributee.

Section 408(d)(3) provides an exception to income inclusion under section 408(d)(1) for
certain distributions from an IRA to the individual for whose benefit the IRA is
maintained that are rolled over within 60 days to another IRA for the benefit of that
individual.

Section 408(d)(3)(C) provides that amounts from an inherited IRA cannot be rolled over
into another IRA. Under section 408(d)(3)(C)(ii), an IRA is treated as an inherited IRA if
the individual for whose benefit the IRA is maintained acquired the IRA by reason of the
death of another individual, and such individual is not the surviving spouse of the other
individual.

Section 1.408-2(b)(8) provides that the term beneficiaries on whose behalf an IRA is
established includes (except where the context indicates otherwise) the estate of the
PLR-104779-21                                 7

individual, dependents of the individual, and any person designated by the individual to
share in the benefits after the death of the individual.

Section 1.408-8, Q&A-1(a), provides that an IRA is subject to the required minimum
distribution rules provided in section 401(a)(9). In order to satisfy section 401(a)(9), the
rules of §§ 1.401(a)(9)-1 through 1.401(a)(9)-9 must be applied, except as otherwise
provided.

Section 1.408-8, Q&A-1(b), provides, as relevant, that for purposes of applying the
required minimum distribution rules in §§ 1.401(a)(9)-1 through 1.401(a)(9)-9, the IRA
trustee, custodian or issuer is treated as the plan administrator, and the IRA owner is
substituted for the employee.

Section 1.408-8, Q&A-3, provides that in the case of distributions from an IRA, the term
“required beginning date” means April 1 of the calendar year following the calendar year
in which the individual attains age 70 ½.

Revenue Ruling 78-406, 1978-2 C.B. 157, provides that the trustee-to-trustee transfer of
funds from one IRA maintained by an individual to another IRA maintained by the same
individual, even at the direction of that individual, does not constitute a payment or
distribution includible in gross income.

The Further Consolidated Appropriations Act, 2020, P. L. 116-94 (the Act), was enacted
on December 20, 2019. Section 401 of Division O of the Act, titled “Setting Every
Community Up for Retirement Enhancement Act of 2019” (SECURE Act), amended
section 401(a)(9) with respect to individuals who die after December 31, 2019. The
amended provisions do not apply in this case because Decedent A died before the
applicability date of the SECURE Act amendments.

Analysis

Under the facts presented, Trust T is the named beneficiary of IRA X. Trust T was
established by Decedent A, was valid under the laws of State S, and became
irrevocable at the death of Decedent A. In addition, relevant documentation relating to
Trust T’s status as beneficiary of Decedent A’s interest in IRA X was given to IRA X’s
custodian by the date required under § 1.401(a)(9)-4, Q&A-6(b). Further, the
beneficiaries of Trust T who are beneficiaries with respect to Trust T’s interest in IRA X
are identifiable, within the meaning of § 1.401(a)(9)-4, Q&A-1, because these
beneficiaries are the three children.

The facts indicate that Trust T satisfies the four requirements of § 1.401(a)(9)-4,
Q&A-5(b), to be treated as a “see-through” trust. Therefore, the three child beneficiaries
of Trust T are treated as having been designated as beneficiaries of IRA X for purposes
of section 401(a)(9).
PLR-104779-21                                 8

In this case, under § 1.401(a)(9)-5, Q&A-7, because more than one beneficiary is
designated as a beneficiary, the beneficiary with the shortest life expectancy is the
designated beneficiary for purposes of determining the applicable distribution period
under § 1.401(a)(9)-4, A-4. In this case, Child C is the beneficiary with the shortest life
expectancy. In addition, because Decedent A’s surviving spouse is not the sole
beneficiary, the rule of § 1.401(a)(9)-5, Q&A-5(c)(1), applies.

With respect to your first ruling request, § 1.401(a)(9)-4, Q&A-5(c), specifically
precludes the separate account treatment described in § 1.401(a)(9)-8, Q&A-2(a), for
purposes of determining the distribution period under section 401(a)(9), for beneficiaries
of a trust with respect to a trust’s interest as beneficiary of an IRA after the death of the
IRA owner. Accordingly, the child beneficiaries of Trust T with respect to the trust’s
interest in IRA X must all be taken into account for purposes of determining the
applicable distribution period that applies to each transferee IRA for purposes of
section 401(a)(9).

However, because § 1.401(a)(9)-4, Q&A-5(c), is specifically applicable only to the
determination of the distribution period under section 401(a)(9), § 1.401(a)(9)-4,
Q&A-5(c), does not otherwise preclude the creation of separate accounts as described
in § 1.401(a)(9)-8, Q&A-2(a)(2), for beneficiaries of a trust with respect to a trust’s
interest as beneficiary of an IRA after the death of the IRA owner. Accordingly, each
transferee IRA may be maintained separately for purposes of section 401(a)(9) except
for purposes of determining the applicable distribution period.

With respect to your second ruling request, the facts indicate that each child beneficiary
intends to accomplish a trustee-to-trustee transfer to separate that beneficiary’s interest
from the other beneficiaries’ interests in IRA X. Such transfers will be into three
separate IRAs established and maintained in the name of “Trust T fbo (name of child
beneficiary), as beneficiary of Trust T.”

In this case, consistent with Rev. Rul. 78-406, the portion of IRA X that is, in effect,
maintained in the name of Trust T for the benefit of a child beneficiary, as beneficiary of
Trust T is being separated from the portions maintained for the benefit of the other child
beneficiaries and is being transferred to another IRA maintained in the name of Trust T
for the benefit of that child beneficiary, as beneficiary of Trust T, with no other change in
title from the transferor IRA to the transferee IRA. Therefore, such transfers do not
constitute taxable distributions under section 408(d)(1) or rollovers under section
408(d)(3).

With respect to your third ruling request, section 401(a)(9)(A)(2) provides that a trust will
not be considered qualified unless the plan provides that the entire interest of each
employee will be distributed, beginning no later than the required beginning date, over
the life of such employee or over the lives of such employee and a designated
beneficiary or over a period not extending beyond the life expectancy of such employee
or the life expectancy of such employee and a designated beneficiary. Decedent A was
PLR-104779-21                                 9

the designated beneficiary of IRA Y, for which Decedent B was the employee.
Therefore, the remaining interest in IRA Y must be distributed following Decedent A’s
death over a period not extending beyond the life expectancy of Decedent A.
Accordingly, required minimum distributions from each child beneficiary’s transferee IRA
derived from IRA Y must continue to be distributed at the same rate as distributions
have been made from IRA Y to Trust T following Decedent B’s death, over a period
calculated using the remaining life expectancy of Decedent A.

With respect to your fourth ruling request, the facts indicate that each child beneficiary
intends to accomplish a trustee-to-trustee transfer to separate that beneficiary’s interest
from the other beneficiaries’ interests in IRA Y. Such transfers will be into three
separate IRAs established and maintained in the name of “Decedent B fbo (name of
child beneficiary), as beneficiary of Decedent A.”

In this case, consistent with Rev. Rul. 78-406, the portion of IRA Y that is, in effect,
maintained in the name of Decedent B for the benefit of a child beneficiary, as
beneficiary of Decedent A is being separated from the portions maintained for the
benefit of the other child beneficiaries and is being transferred to another IRA
maintained in the name of Decedent B for the benefit of that child beneficiary, as
beneficiary of Decedent A, with no other change in title from the transferor IRA to the
transferee IRA. Therefore, such transfers do not constitute taxable distributions under
section 408(d)(1) or rollovers under section 408(d)(3).

Rulings

Thus, with respect to your ruling requests, we conclude as follows:

1. Each child beneficiary of Trust T is treated as having been designated as a
beneficiary of IRA X in accordance with § 1.401(a)(9)-4, Q&A-5, for purposes of
determining the distribution period under section 401(a)(9). Required minimum
distributions from IRA X are calculated using the life expectancy of Child C, the oldest
child beneficiary.

2. The trustees of Trust T may transfer the assets of IRA X by means of trustee-to-
trustee transfers to IRAs titled IRA of “Trust T fbo (name of child beneficiary), as
beneficiary of Trust T” in order to separate the interest of each child beneficiary in the
assets of IRA X, without such transfers constituting taxable distributions under section
408(d)(1) or rollovers under section 408(d)(3).

3. Required minimum distributions from IRA Y are calculated using the life expectancy
of Decedent A.

4. The trustees of Trust T may transfer the assets of IRA Y by means of trustee-to-
trustee transfers to IRAs titled IRA of “Decedent B fbo (name of child beneficiary), as
beneficiary of Decedent A” in order to separate the interest of each child beneficiary in
PLR-104779-21                                  10

the assets of IRA Y, without such transfers constituting taxable distributions under
section 408(d)(1) or rollovers under section 408(d)(3).

This letter assumes that IRA X and IRA Y have satisfied the requirements of section
408 at all times relevant thereto. It also assumes that the transferee IRAs to be set up
by the child beneficiaries will meet the requirements of section 408 at all times relevant
thereto.

The rulings contained in this letter are based upon information and representations
submitted by Trust T and accompanied by a penalties of perjury statement executed by
an appropriate party, as specified in Rev. Proc. 2021-1, 2021-1 I.R.B. 1, § 7.01(16)(b).
This office has not verified any of the material submitted in support of the request for
ruling, and such material is subject to verification on examination. The Associate office
will revoke or modify a letter ruling and apply the revocation retroactively if there has
been a misstatement or omission of controlling facts; the facts at the time of the
transaction are materially different from the controlling facts on which the ruling was
based; or, in the case of a transaction involving a continuing action or series of actions,
the controlling facts change during the course of the transaction. See Rev. Proc. 2021-
1, § 11.05.

Except as expressly provided above, no opinion is expressed or implied concerning the
federal income tax consequences of any other aspects of any transaction or item of
income described in this letter ruling.

This letter is directed only to the taxpayer requesting it. Section 6110(k)(3) provides that
it may not be used or cited as precedent.

In accordance with the Power of Attorney on file with this office, a copy of this letter is
being sent to your authorized representatives.

                                           Sincerely,


                                           /s/ Neil Sandhu
                                           ______________________________
                                           Neil Sandhu
                                           Senior Technician Reviewer
                                           Qualified Plans Branch 1
                                           Office of the Associate Chief Counsel
                                           (Employee Benefits, Exempt Organizations,
                                           and Employment Taxes)



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