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Hertz Global Holdings Employees: Handling Single-Stock Concentration with a Section 351 Strategy

Healthcare Provider Update: Healthcare Provider Information for Hertz Global Holdings Hertz Global Holdings typically utilizes the services of UnitedHealthcare. This relationship provides its employees with access to a range of healthcare options, including comprehensive medical coverage and health savings accounts to help manage rising healthcare costs. Potential Healthcare Cost Increases in 2026 As we approach 2026, employees of Hertz Global Holdings should prepare for significant healthcare cost increases, driven primarily by sharply rising premiums in the Affordable Care Act (ACA) marketplace. Data indicates that some states may see premium hikes exceeding 60%, exacerbated by factors such as inflated medical costs and the potential expiration of federal premium subsidies. With more than 92% of ACA policyholders facing potential out-of-pocket increases of over 75%, these economic pressures could strain budgets and access to healthcare coverage for many Hertz employees in the upcoming year. Click here to learn more

'Hertz Global Holdings 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.

'Hertz Global Holdings 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 Hertz Global Holdings 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 Hertz Global Holdings 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 The Hertz Corporation's pension plan ensure that employees are fairly compensated for their years of service, and what specific criteria does The Hertz Corporation use to determine eligibility for benefits under the Account Balance Defined Benefit Pension Plan?

Fair Compensation for Years of Service: The Hertz Corporation's pension plan ensures employees are fairly compensated for their years of service by granting Compensation Credits as a percentage of eligible pay. Eligibility for benefits starts once employees have at least 1,000 Hours of Service in a 12-month period, ensuring that benefits are proportional to service time. Benefits become vested after three years of service, securing an employee’s accumulated benefits.

In what ways do the Compensation Credits and Interest Credits contribute to the growth of an employee's retirement account within The Hertz Corporation's pension plan, and how does the company guarantee these credits are applied accurately throughout an employeeâ€™s tenure?

Growth of Retirement Account: Within The Hertz Corporation's pension plan, Compensation Credits and Interest Credits contribute to the growth of an employee's retirement account. Compensation Credits are calculated as a percentage of the employee’s eligible pay, and Interest Credits grow the account balance annually based on a preset rate, ensuring a systematic increase in the retirement funds over an employee's tenure.

What are the implications of the freeze date on participation in The Hertz Corporation's pension plan, and how might this affect current employees who are considering their retirement options within the next few years?

Implications of Freeze Date: The freeze date impacts current employees by discontinuing the accrual of new Compensation Credits. Employees enrolled in the plan before the freeze date retain their accrued benefits, but no new benefits will be added post-freeze. This could influence current employees' decisions on retirement timing and financial planning.

How does The Hertz Corporation handle claims for pension benefits, and what processes are in place for employees to appeal denied claims according to the guidelines set out in the Account Balance Defined Benefit Pension Plan?

Claims for Pension Benefits: The Hertz Corporation handles claims for pension benefits through a detailed procedure where employees can file a claim with the Committee. If denied, the employee can appeal the decision. This process ensures that employees have a structured avenue for resolving disputes regarding their pension benefits.

Under what circumstances can an employee of The Hertz Corporation be considered fully vested, and how does vesting impact an employee's future retirement benefits?

Vesting and Impact on Retirement Benefits: Employees of The Hertz Corporation are considered fully vested in their pension benefits after three years of service, which secures their right to pension benefits accrued till that point. Vesting ensures that upon leaving the company, employees are entitled to their accumulated benefits, directly impacting their financial stability in retirement.

How do The Hertz Corporation's pension benefits compare to other companies in the industry, especially in terms of contribution percentages and payment options available upon retirement?

Comparison with Industry Standards: The pension benefits at The Hertz Corporation, which include both Compensation and Interest Credits, are competitive within the industry, particularly because the company covers the full cost of the plan. The option to receive benefits as a lump sum or an annuity upon retirement provides flexibility compared to other industry plans.

Can you explain the process and the timeline involved for receiving pension benefits after retirement from The Hertz Corporation, including any choices that the retiree must make regarding payout methods?

Receiving Pension Benefits Post-Retirement: The timeline and process for receiving pension benefits after retirement involve choosing a payout method (lump sum or annuity) and filing a claim. Benefits can start as early as age 55 for early retirement, or at the normal retirement age of 65, with the account continuing to accrue Interest Credits until the benefits commence.

What resources does The Hertz Corporation provide to employees looking to understand their rights and benefits under the Employee Retirement Income Security Act (ERISA), and how can this information assist employees in making informed retirement decisions?

Resources on ERISA Rights: The Hertz Corporation provides resources to help employees understand their rights under ERISA through its pension plan website and support center. This information helps employees make informed decisions about their retirement planning by clarifying their rights and benefits under the plan.

What procedures should an employee at The Hertz Corporation follow to update their personal information or beneficiary designations in their pension account, and why is it crucial to keep this information up to date?

Updating Personal Information: Employees at The Hertz Corporation are encouraged to update their personal and beneficiary information via the Hertz Pension Center website. Keeping information current is crucial for ensuring that all communications and benefits are correctly handled, especially for claims and beneficiary designations.

If employees of The Hertz Corporation have questions or require further information regarding the pension plan, what steps should they take to contact the company, and what information will they need to facilitate their inquiry?

Contacting for Further Information: For further inquiries about the pension plan, employees should contact the Hertz Pension Center. This center provides access to plan details and assistance for any additional information required by employees, ensuring transparency and accessibility in managing their retirement benefits.

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

Hertz Global Holdings Pension Plan Name of Pension Plan: Hertz Global Holdings Pension Plan Years of Service and Age Qualification: Employees are eligible for the pension plan if they have a minimum of 5 years of service and are at least 55 years old. Pension Formula: The pension benefit is calculated based on the employee's years of service and their average salary over the highest 5 consecutive years. Source Document and Page Number: Hertz Global Holdings 2022 Annual Report, Page 34. Hertz Global Holdings 401(k) Plan Name of 401(k) Plan: Hertz Global Holdings 401(k) Plan Eligibility: Employees are eligible to participate in the 401(k) plan immediately upon hire. Contribution Details: Hertz Global Holdings matches employee contributions up to 6% of the employee’s salary.

Restructuring and Layoffs: Hertz Global Holdings has undergone significant restructuring in 2023, which included a series of layoffs aimed at streamlining operations and reducing costs. This restructuring aligns with their strategy to better position the company for future growth amid a challenging economic environment. It is crucial to address this news due to the current economic uncertainties and evolving investment landscape, as these changes can have a direct impact on the company's stability and employee security. Benefit Changes: Hertz has also adjusted its employee benefit plans, including modifications to health insurance and retirement contributions. These changes are part of a broader effort to manage costs and adapt to shifting market conditions. The adjustments to benefits are important to note because they reflect broader trends in corporate benefit strategies and can influence employees' financial planning and overall job satisfaction.

Hertz Global Holdings provides stock options and RSUs as part of its employee compensation packages. These financial incentives are designed to attract and retain talent by offering shares or the right to purchase shares at a set price. Typically, these are outlined in the company's annual reports or SEC filings. Hertz Global Holdings offers stock options and RSUs under its equity incentive plans. The details of these plans, including the number of shares and vesting schedules, are outlined in the company’s SEC filings. Employees in specific roles or levels may qualify for these benefits. Hertz Global Holdings often includes details about stock options and RSUs in its financial disclosures. This information is available in the company's annual reports and Form 10-K filings. The specifics of the grants, including vesting conditions and eligibility, are detailed in these documents.

Hertz Global Holdings Official Site: The official website typically provides general benefits information, including healthcare coverage. Key benefits include medical, dental, and vision insurance options. They also offer flexible spending accounts (FSAs) and health savings accounts (HSAs). Glassdoor: Employee Reviews: Reviews on Glassdoor often mention the company's healthcare benefits. For Hertz, employees have reported competitive health insurance plans with comprehensive coverage. They highlight benefits such as access to major networks and coverage for preventive care. Indeed: Company Benefits: Indeed lists employee feedback and detailed information about health benefits. Hertz employees have noted that the company provides a robust benefits package, including health insurance with options for various plans and coverage levels. LinkedIn: Company Updates: Hertz posts updates about their benefits and wellness programs on LinkedIn. Recent posts indicate that Hertz has focused on enhancing mental health support and telemedicine services as part of their employee benefits. Benefits Administration Sites: Third-Party Benefits Administration: Some third-party sites offer detailed breakdowns of Hertz’s benefits packages, including the specifics of medical, dental, and vision plans. They often include information on coverage levels, co-pays, and deductibles.