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Company:
Genuine Parts
Plan Administrator:
,
'Genuine Parts 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.
'Genuine Parts 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 Genuine Parts 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 Genuine Parts 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.
As you plan your transition from Genuine Parts into retirement, understanding the company's benefit structure can help you make more informed decisions. According to publicly available information, Genuine Parts maintains an active defined benefit pension plan, which provides retirement income based on factors such as years of service and compensation history. Genuine Parts does not appear to offer a formal retiree healthcare program, making healthcare coverage planning an important consideration if you retire before age 65. Because the specifics of your pension formula, vesting schedule, and benefit eligibility depend on your individual employment history and plan documents, We encourage you to review your Summary Plan Description (SPD) or speak with Genuine Parts's HR or benefits team for the most current details.
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.
What benefits does the GPC Pension Plan provide to employees of Genuine Parts Company, and how are these benefits calculated for both Group 1 and Group 2 employees? In the context of Genuine Parts Company, what are the critical factors that determine the pension benefits for employees and how have recent changes to the plan affected these calculations?
The benefits of the GPC Pension Plan for Genuine Parts Company employees are calculated based on the employee’s Final Average Monthly Earnings (FAME) and years of Credited Service. For Group 1 employees, benefits are frozen as of December 31, 2013, with the FAME calculated from the five highest-paid years within the last ten years of service before that date. For Group 2 employees, benefits are similarly frozen as of December 31, 2008, and the same calculation of FAME is applied using the highest earnings before that freeze date(Genuine Parts Company_P…).
How do the eligibility requirements of the GPC Pension Plan differ between Group 1 and Group 2 employees at Genuine Parts Company? Additionally, what specific service requirements must employees meet to qualify for the benefits under each group, particularly considering the impact of employment history and rehire status on benefits?
Eligibility requirements differ between Group 1 and Group 2 employees. Group 1 includes employees with Rule of 70 status, who opted to continue participation in the plan after January 1, 2009. Group 2 employees, which include those rehired before December 31, 2013, had their Credited Service frozen earlier in 2008. Group 1 employees have Credited Service frozen as of December 31, 2013, while Group 2’s freeze date is December 31, 2008(Genuine Parts Company_P…).
What strategies can employees of Genuine Parts Company consider for optimizing their pension benefits when transitioning to retirement? Are there specific actions that employees should take prior to retirement to enhance their benefit calculations under the GPC Pension Plan, particularly in relation to Credited Service and Final Average Monthly Earnings?
To optimize pension benefits, Genuine Parts Company employees should focus on maximizing Credited Service and Final Average Monthly Earnings (FAME). Ensuring a full work history before the freeze date (2013 for Group 1, 2008 for Group 2) can enhance the benefit calculation. Employees can also review their Social Security benefit estimates, which are considered in calculating their pension(Genuine Parts Company_P…).
How does the vesting process work for employees participating in the GPC Pension Plan at Genuine Parts Company, and what implications does it have for those contemplating early retirement? Furthermore, how does the ability to vest at different service intervals specifically impact the retirement planning of employees?
The vesting process for the GPC Pension Plan requires employees to accumulate vesting service years, which continues even after the freeze date. Employees are automatically fully vested after seven years of service, or if they worked at least one hour after December 31, 2013. Vesting ensures the right to the earned pension benefits, which may affect retirement planning, especially for those contemplating early retirement(Genuine Parts Company_P…).
What information should Genuine Parts Company employees know about the different forms of payment available under the GPC Pension Plan once they reach retirement age? How do options such as life annuities and lump-sum payments affect the overall financial planning for retiring employees?
Genuine Parts Company employees can choose from various forms of pension payments upon retirement, including life annuities, joint and survivor annuities, and lump-sum payments. Each option affects financial planning differently: life annuities provide steady income, while lump sums offer flexibility but require careful management to ensure long-term financial stability(Genuine Parts Company_P…).
In the event of a termination of employment, what options are available for employees of Genuine Parts Company to access their pension benefits under the GPC Pension Plan? Additionally, what are the specific procedures that employees must follow to ensure they receive their benefits in a timely manner?
In the event of termination, employees who are vested can access their pension benefits, either at their normal retirement age or earlier if they meet the eligibility criteria for early retirement. Employees must submit a request within 180 days of their termination date to receive benefits, with options for lump sum payments for amounts under $75,000(Genuine Parts Company_P…)(Genuine Parts Company_P…).
How can employees of Genuine Parts Company ensure that their beneficiaries are appropriately named under the GPC Pension Plan? What considerations should employees keep in mind when designating beneficiaries, particularly understanding consent needs for spouses and the impact of domestic relations orders?
Genuine Parts Company employees should ensure their beneficiaries are properly named, particularly if married. A spouse is the default beneficiary, but spousal consent is required if an employee designates someone else. Domestic relations orders may also affect beneficiary designations(Genuine Parts Company_P…).
What unique situations might affect the pension benefits of employees at Genuine Parts Company, and how does the plan specifically address employees on military leave or long-term disability? In these circumstances, what communication strategies should employees employ to navigate their benefits?
For employees on military leave or long-term disability, the GPC Pension Plan provides special rules for calculating benefits. These employees should maintain close communication with the Employee Service Center to ensure their benefits are appropriately adjusted(Genuine Parts Company_P…).
Regarding the reporting and update of personal information, why is it essential for employees of Genuine Parts Company to keep the GPC Employee Service Center informed about any changes in marital status or address? How can failure to report these changes potentially impact the pension benefits they receive?
Employees must keep the GPC Employee Service Center informed of any changes in marital status or address, as failure to do so could result in delayed or incorrect pension benefit payments(Genuine Parts Company_P…).
How can employees at Genuine Parts Company reach out for further clarification on the details presented in the Summary Plan Description of the GPC Pension Plan? What resources or contact points are available that could assist in navigating the complexities of the pension plan, ensuring employees can maximize their benefits effectively?
Genuine Parts Company employees can reach out to the GPC Retirement Plan Services through their toll-free number or website for clarification on the pension plan details. These resources are crucial for navigating the complexities of the pension system(Genuine Parts Company_P…).
For more information you can reach the plan administrator for Genuine Parts at , ; or by calling them at .
http://ww38.attbenefitscenter.com/?subid1=20240815-0154-48ab-b89b-72ae782016d3
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