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Entergy Employees: Handling Single-Stock Concentration with a Section 351 Strategy

Healthcare Provider Update: For Entergy, the healthcare provider is typically UnitedHealthcare, which offers a range of health insurance plans to its employees and their families. As the backdrop of rising healthcare costs intensifies, Entergy may face significant healthcare cost increases in 2026. With the upcoming expiration of enhanced federal premium subsidies, millions of Americans could experience a staggering jump in monthly out-of-pocket costs-potentially exceeding 75% for those benefiting from the Affordable Care Act marketplace. Factors contributing to these surges include aggressive premium hikes from major insurers, coupled with higher medical costs attributed to inflation and increased healthcare utilization. As such, it will be imperative for Entergy and its employees to strategize and prepare for these escalating expenses to mitigate financial impacts in the coming year. Click here to learn more

'Entergy employees with concentrated stock positions should understand that strategies like a Section 351 exchange can offer flexibility in managing large unrealized gains while preserving long-term planning options.' – Tyson Mavar, a representative of The Retirement Group, a division of Wealth Enhancement.

'Entergy employees facing concentrated stock exposure may find that a Section 351 exchange provides an effective way to mitigate risk and maintain control over the timing of potential tax liabilities.' – Wesley Boudreaux, a representative of The Retirement Group, a division of Wealth Enhancement.

In this article, we will discuss:

When a Section 351 exchange can help diversify concentrated stock positions without an immediate tax bill.
The core eligibility rules (80% control test) and basis/step-up mechanics that drive tax deferral.
Sample case studies (James & Sarah) illustrating the numbers and outcomes.

The Strategic Potential of Section 351: An Analysis of a Multi-Stock Case in Tax-Deferred Reorganization

A sizable amount of the wealth of many high-earning professionals at Entergy may be invested in a small number of highly valued equities, including company shares accumulated through restricted stock units (RSUs), the employee stock purchase plan (ESPP), or equity awards earned due to long tenure. While rebalancing may seem out of reach due to the tax ramifications of selling these positions, investors can make tax-deferred contributions of appreciated assets to a new business entity through a Section 351 exchange. When an investor wants to manage several sizable, embedded gains at once, this tactic may be especially useful.

Think about James, a client with a $10 million portfolio. The value of one stock investment, which he purchased for $50,000, has increased to $1 million, or 10% of his total portfolio. At a long-term capital gains rate that can reach 23.8% for certain high-income taxpayers (20% maximum long-term capital gains rate plus the 3.8% Net Investment Income Tax), selling this position would result in a $950,000 capital gain and an estimated $226,100 tax bill. The amount available for reinvestment would be reduced by this tax.

Section 351(a) of the Internal Revenue Code provides: “If property is transferred to a corporation by one or more persons solely in exchange for stock in such corporation and immediately after the exchange such person or persons are in control (as defined in section 368(c)) of the corporation, no gain or loss shall be recognized.” Under Section 368(c), “control” generally means ownership of at least 80% of the voting power and 80% of each class of non-voting shares.

The transferor or transferors must own at least 80% of the new corporation’s stock right after the exchange to qualify for this treatment. This can be done for investors with sizable portfolios by joining a larger seeding group or acting as the principal seeder of a new entity.

In a Section 351 transaction, any built-in gains are preserved because the shareholder’s basis in the received stock typically carries over from the contributed property. If the shares are held until death, a step-up in basis under Section 1014 may eliminate the deferred gain.

Another client example involves Sarah, who has a $13 million portfolio. She owns two appreciated stocks:

Stock A: Originally $300,000, now worth $3 million.
Stock B: Initial cost basis $500,000, now worth $3 million.

At a long-term capital gains rate that can reach 23.8% for certain high-income taxpayers, the aggregate unrealized gain of $5.2 million would translate into an estimated tax of roughly $1,237,600 if sold today, which can constrain portfolio adjustments.

For employees of Entergy holding concentrated positions, taking part in a Section 351 exchange can reduce concentration risk and defer recognition of these gains without an immediate tax bill. If assets receive a step-up in basis at death, the deferred gain may be fully eliminated under current law, and deferral can provide flexibility in managing future tax obligations.

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Sources:

1. Internal Revenue Service. Revenue Ruling 2003-51 . Internal Revenue Bulletin 2003-21, 2003. PDF.

2. Friedel, David B., and Yaw O. Awuah. “ Sec. 351 Control Requirement: Opportunities and Pitfalls .” The Tax Adviser , 1 July 2014. Web.

3. Internal Revenue Service. “ Net Investment Income Tax (NIIT) .” IRS.gov , last reviewed 1 July 2025. Web.

4. Internal Revenue Service. Publication 551: Basis of Assets . December 2024 revision, posted 18 February 2025. PDF.

5. FINRA Investor Education Foundation (FINRA). “ Concentrate on Concentration Risk .” FINRA.org , 15 June 2022. Web.

How does Entergy Nuclear Operations, Inc. determine the eligibility criteria for employees participating in the pension plan, and what specific conditions must be met for an employee to qualify for benefits under Appendix G of the Plan?

Eligibility Criteria for Pension Plan: Entergy Nuclear Operations, Inc. determines pension eligibility based on Vesting Service and age. Employees generally become 100% vested after five years of service or upon reaching age 61 while employed. Special provisions may apply to employees who participated in the Vermont Yankee Plan as of July 31, 2002(Entergy_Nuclear_Operati…).

What are the specific steps and necessary documentation required for an employee of Entergy Nuclear Operations, Inc. to commence their pension benefits once they reach retirement age, and how does this process differ for those with previous employment at other participating companies?

Commencing Pension Benefits: To commence pension benefits, an employee must file an application with the Entergy Pension Resource Center (EPRC). This includes providing necessary documentation, such as proof of age and employment history. Employees who have worked for other participating companies must account for service under prior employers, which may impact the pension calculation(Entergy_Nuclear_Operati…).

In what ways does Entergy Nuclear Operations, Inc. ensure that employees understand their rights under the Employee Retirement Income Security Act (ERISA), and what resources are available for employees seeking clarification on their pension benefits?

ERISA Rights and Resources: Entergy Nuclear Operations, Inc. ensures employees understand their rights under the Employee Retirement Income Security Act (ERISA) by providing access to the plan documents and offering assistance through the Entergy Pension Resource Center. Employees can request clarification on pension benefits by contacting EPRC(Entergy_Nuclear_Operati…).

How does the non-bargaining and bargaining employee classification at Entergy Nuclear Operations, Inc. impact the pension benefits available, and what should employees consider when planning for retirement in light of these classifications?

Impact of Non-Bargaining and Bargaining Classifications: The classification between non-bargaining and bargaining employees affects pension benefits. Non-bargaining employees are covered under Appendix G of the Plan, which may provide different accrual rates and benefit options compared to bargaining employees. These classifications impact retirement planning, as different rules may apply depending on the classification(Entergy_Nuclear_Operati…).

What provisions are in place at Entergy Nuclear Operations, Inc. for beneficiaries to receive benefits upon an employee's death, and how do these benefits differ based on whether the employee had already commenced their pension?

Death Benefits for Beneficiaries: In the event of an employee's death, the Entergy pension plan provides benefits to beneficiaries. If the employee has already commenced pension payments, the form of payment selected will determine the survivor benefits. If the employee passes away before starting pension benefits, the spouse may receive pre-retirement survivor benefits(Entergy_Nuclear_Operati…).

How does Entergy Nuclear Operations, Inc. calculate the normal retirement pension, and what factors play a crucial role in determining an employee's monthly benefit under Appendix G of the Plan?

Pension Calculation Factors: The normal retirement pension at Entergy Nuclear Operations, Inc. is calculated using a formula based on Average Earnings and years of Benefit Service. The formula includes percentages of earnings, capped at certain limits, and service years to determine the monthly pension benefit under Appendix G(Entergy_Nuclear_Operati…).

What unique considerations should employees of Entergy Nuclear Operations, Inc. keep in mind regarding service credits, particularly if they have accrued time under a prior employer's defined benefit plan?

Service Credits for Prior Employers: Employees with service under a prior employer's defined benefit plan may have their service credited toward the pension plan at Entergy Nuclear Operations, Inc. This includes specific provisions for employees from companies like Vermont Yankee. Service credits from prior employers may affect both vesting and benefit calculations(Entergy_Nuclear_Operati…).

How does Entergy Nuclear Operations, Inc. handle the transition of employees who transfer from covered employment with the potential for pension benefits, and what impact does this have on their accrued service time?

Impact of Employee Transfers on Pensions: If an employee transfers from covered employment (i.e., eligible for the pension plan) to a position not covered by the plan, their Benefit Service is frozen. However, Vesting Service continues to accrue as long as the employee remains with the company, and previous service may impact final pension benefits(Entergy_Nuclear_Operati…).

What specific contact methods are available for employees of Entergy Nuclear Operations, Inc. to reach the Entergy Pension Resource Center for assistance regarding their pension benefits, and what type of inquiries can the center effectively handle?

Contacting the Entergy Pension Resource Center: Employees can contact the Entergy Pension Resource Center (EPRC) for assistance with their pension benefits via phone at 1-855-523-3772 or online at EPRC Website. Inquiries can include questions about benefits, beneficiary designations, and how to commence pension payments(Entergy_Nuclear_Operati…).

In what scenarios might an employee's pension benefits at Entergy Nuclear Operations, Inc. be suspended, and what steps can be taken to appeal or rectify such situations once they occur?

Suspension of Pension Benefits: Pension benefits may be suspended if an employee is rehired after retirement and works more than 40 hours in a month. Employees who experience benefit suspensions can have their pension recalculated upon final retirement, with offsets for any benefits previously received(Entergy_Nuclear_Operati…).

With the current political climate we are in it is important to keep up with current news and remain knowledgeable about your benefits.

Entergy Corporation offers a robust retirement plan system for its employees, which includes both pension and 401(k) options. The Entergy Corporation Retirement Plan for Non-Bargaining Employees transitioned to a Cash Balance Plan on July 1, 2014, and underwent further amendments in 2023 and 2024. As of January 1, 2024, accrued benefits for specific participants were transferred to the Entergy Corporation Retirement Plan VI for Non-Bargaining Employees. This shift includes participants who were previously under Appendix J of the former retirement plan, now governed by the new Appendix J of Plan VI (SEC.gov). The pension plan utilizes a Cash Balance Equalization formula, which was initially implemented in 2014 and amended in 2023. The plan stipulates that employees accumulate retirement credits based on their compensation and service, with an annual interest credit added to their retirement accounts. Non-bargaining employees with at least five years of service qualify for this pension plan

Entergy announced in early 2024 a significant restructuring plan aimed at optimizing its operational efficiency. This includes streamlining operations and reducing overhead costs. The plan involves job cuts in non-essential roles and is part of a broader effort to enhance financial stability amid changing energy market conditions. Source: Business Insider

In 2022, Entergy Corporation granted stock options and RSUs as part of their long-term incentive plan. Stock options were available to executives and senior management, while RSUs were provided to a broader group of employees including middle management and high performers. Entergy typically uses the acronym "SO" for stock options and "RSU" for restricted stock units.

Entergy Health Benefits Overview 1. Official Website Website: Entergy Careers Benefits Information: Entergy offers a comprehensive benefits package that includes medical, dental, and vision coverage. They provide a range of plans with varying levels of coverage and cost-sharing options. Employees can also access wellness programs and preventive care services. 2. Benefits Information Website: Entergy Benefits Summary Benefits Information: Entergy's benefits summary highlights health insurance options, including PPO and HMO plans, a Health Savings Account (HSA), and Flexible Spending Accounts (FSA). They also offer mental health support and employee assistance programs. 3. News and Updates Website: Business Insider Recent News: In 2023, Entergy updated its health benefits plan to include enhanced telehealth services and expanded mental health resources in response to increased employee demand and well-being concerns. 4. Healthcare Terms and Acronyms Website: HR Dive Healthcare Terms: Common terms include HSA (Health Savings Account), FSA (Flexible Spending Account), PPO (Preferred Provider Organization), HMO (Health Maintenance Organization), and EAP (Employee Assistance Program). 5. Employee Healthcare News Website: Employee Benefits News Recent News: In 2024, Entergy introduced new wellness initiatives, such as on-site health clinics and enhanced maternity benefits, aimed at improving overall employee health and reducing absenteeism