Net Unrealized Appreciation (NUA): The Company Stock Distribution Strategy

Lump-Sum Distribution • NUA at Capital Gains Rates • Cost Basis Ordinary Income • When It Beats a Rollover
IRC §402(e)(4)Rev. Rul. 81-122Form 1099-R
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When a participant holds appreciated employer stock inside a 401(k) or other qualified plan, there is a strategy that can convert what would be ordinary income on an IRA rollover into long-term capital gain: the net unrealized appreciation (NUA) distribution. Instead of rolling the entire account to an IRA - where all future distributions are taxed as ordinary income - the participant takes a lump-sum distribution of the employer stock in-kind. The cost basis is taxed as ordinary income. The NUA - the appreciation inside the plan - is taxed as long-term capital gain when the stock is eventually sold, regardless of how long the stock is held after distribution.

NUA in Plain Terms

Without NUA strategy: Roll 401(k) (including company stock) to IRA. All future distributions taxed as ordinary income at your marginal rate - including the appreciation on company stock that built up inside the plan over decades.

With NUA strategy: Take a lump-sum distribution of the employer stock in-kind. Pay ordinary income tax on the cost basis (what the plan paid for the shares). The NUA - everything above that cost basis - is taxed at long-term capital gains rates (0%, 15%, or 20%) when you eventually sell. No ordinary income on the NUA regardless of holding period after distribution.

The Four Requirements for NUA Treatment

IRC §402(e)(4) requires all of the following: (1) a lump-sum distribution - the entire account balance from all plans of the same type must be distributed in a single tax year; (2) from a qualified plan (401(k), profit-sharing, pension - not IRAs); (3) after a triggering event - separation from service, reaching age 59½, death, or disability; and (4) the distribution includes employer securities (company stock held inside the plan). All four must be present. A partial distribution or a distribution from only some of the plans does not qualify.

The lump-sum requirement is strict and frequently misunderstood. "Lump-sum" means the entire vested balance from all qualified plans of the employer must be distributed in one tax year. If you have a 401(k) and a separate pension from the same employer, both must be distributed. If you take the 401(k) but leave the pension, you lose NUA treatment. Plan carefully before triggering the distribution.

When NUA Beats a Rollover

NUA is most valuable when: the cost basis inside the plan is low relative to the current value (large NUA), the participant is in a high ordinary income bracket (so the IRA rollover would be taxed at 37%), and long-term capital gains rates (20% + 3.8% NIIT at high incomes) are meaningfully lower than the marginal ordinary income rate. The math typically favors NUA when cost basis is less than 30-40% of current value. When cost basis is high - meaning the stock has not appreciated much inside the plan - the benefit is minimal and the complexity is not worth it.

The Other Assets in the Lump-Sum

In a lump-sum distribution that qualifies for NUA, only the employer stock gets the NUA benefit. All other assets - cash, mutual funds, bonds - are rolled to an IRA to defer tax. The stock is taken in-kind (actual shares, not cash) and moved to a taxable brokerage account. The employer reports the distribution on Form 1099-R with the cost basis in Box 6 (NUA amount) and Box 2a (taxable amount = cost basis only).

Authority: IRC §402(e)(4) (net unrealized appreciation - special rule for distributions of employer securities; NUA excluded from gross income at distribution; taxed as long-term capital gain when stock is sold regardless of post-distribution holding period; cost basis is ordinary income in year of distribution; lump-sum distribution requirements); IRC §402(e)(4)(B) (lump-sum distribution defined - total balance to credit of employee from all qualified plans of same type distributed in one tax year; triggering event required - death, disability, attaining age 59½, or separation from service); IRC §402(e)(4)(E) (employer securities defined for NUA purposes); Rev. Rul. 81-122 (NUA treatment confirmed for qualifying lump-sum distributions; cost basis reported as taxable at distribution; NUA deferred to sale); Form 1099-R Box 6 (net unrealized appreciation in employer securities - employer reports NUA amount; Box 2a shows only cost basis as taxable amount); IRS Publication 575 (Pension and Annuity Income - NUA section with examples; lump-sum distribution requirements; comparison to rollover); Notice 98-24 (IRS guidance on lump-sum distribution requirements for NUA eligibility).
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