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ROBS & Plan Terms

TermDefinition
ROBSRollover for Business Startups - a legal mechanism to use retirement savings as tax-free startup capital through a C-Corporation and 401(k) plan
401(k) PlanAn employer-sponsored retirement savings plan that allows employees to contribute pre-tax income. In ROBS, the plan also permits investment in employer stock
Qualifying Employer SecuritiesStock issued by the employer that sponsors the plan. In ROBS, this is the C-Corporation stock purchased by the 401(k) plan
Trustee-to-Trustee TransferA direct rollover of retirement funds between plan trustees without the funds passing through the individual. No taxes are triggered
Plan TrustThe trust entity that holds 401(k) plan assets. It is the legal owner of the C-Corp stock purchased through the ROBS transaction. As long as you remain an active plan participant, these shares represent your beneficial ownership in the corporation - you direct the trust’s investment decisions as Plan Administrator.
Adoption AgreementThe document by which the C-Corporation formally adopts the 401(k) plan, specifying its terms and provisions
Trust AgreementEstablishes the trust that holds plan assets and defines the trustee’s fiduciary responsibilities
Funding PolicyThe plan’s investment policy statement, including authorization to invest in employer securities
Plan HighlightsA plain-language summary of plan terms provided to plan participants (required disclosure)
Form 5500Annual return filed with the DOL for employee benefit plans. Required for all 401(k) plans with assets
Plan Trust EINThe Employer Identification Number assigned to the 401(k) plan trust, separate from the C-Corporation’s EIN. Required for annual Form 5500 filings. Talcott Forge files it via CorpTools as part of plan setup.
Adoption Agreement (Execution Page / Addenda)The Adoption Agreement is delivered in two parts: the execution page (pages 1-12) is the signable portion and is sent for electronic signature, while the addenda (pages 13+) contain detailed plan provisions as reference material. Both are stored in your document library.

Tax & Compliance Terms

TermDefinition
IRC 4975Internal Revenue Code section governing prohibited transactions for retirement plans. Violations trigger a 15% excise tax (100% if uncorrected)
ERISAEmployee Retirement Income Security Act - federal law governing employee benefit plans including 401(k)s
ERISA 408(e)ERISA exemption allowing plans to acquire qualifying employer securities for adequate consideration
IRC 4975(d)(13)IRC exemption for transactions exempt under ERISA 408(e) - the legal basis for ROBS
Prohibited TransactionA transaction between a plan and a disqualified person that violates IRC 4975(c). Includes self-dealing, loans, property transfers, and kickbacks
Disqualified PersonA fiduciary, service provider, employer, or 50%+ owner with respect to the plan. As a ROBS founder, you are a disqualified person
FiduciaryA person who exercises discretionary authority over plan management, assets, or administration
Excise TaxA tax imposed on prohibited transactions - 15% of the amount involved per year, plus 100% if not corrected
Adequate ConsiderationThe fair market value standard for transactions involving plan assets. For publicly traded securities, it’s the market price; for private stock, it’s determined by good-faith fiduciary assessment
409A ValuationAn independent appraisal of a private company’s fair market value under IRC 409A. Required for ROBS plan valuations after Year 1
IRS Memo 2008-01-021IRS examination guidance for auditing ROBS transactions. Acknowledges ROBS as a recognized planning strategy while outlining audit procedures
QSBS (Qualified Small Business Stock)Stock in a qualified small business that may be eligible for a federal capital gains exclusion under IRC 1202 (up to 100% exclusion after 5 years). Important: Shares held by a 401(k) plan trust do not qualify for QSBS treatment - QSBS requires direct individual ownership. Shares issued directly to founders (for example, via a fee reimbursement election in shares) may qualify if all other IRC 1202 requirements are met.

Corporate Terms

TermDefinition
C-CorporationA standard corporation taxed separately from its shareholders. Required for ROBS because only C-Corps issue qualifying employer securities
S-CorporationA corporation that elects pass-through taxation under Subchapter S. Cannot be used for ROBS but available for standalone incorporation
LLCLimited Liability Company - a flexible business structure with pass-through taxation. Ownership through membership interests, not stock. Available for standalone incorporation
Par ValueThe minimum nominal value assigned to each share of stock. Standard par value is $0.0001/share for Delaware and Nevada C-Corps. The actual share purchase price is set based on the capitalization structure
Cap TableCapitalization table - a record of all equity ownership, share classes, and transactions for the corporation
Share ClassA category of stock with specific rights (voting, dividends, liquidation preference). ROBS companies typically start with a single class of common stock
Board ResolutionA formal decision by the board of directors, documented in writing. Required for authorizing compensation, stock issuance, and other major corporate actions
BylawsInternal governance rules for the corporation - meeting procedures, officer duties, shareholder rights
Articles/Certificate of IncorporationThe founding document filed with the state to legally create the corporation
Articles of OrganizationThe founding document filed with the state to legally create an LLC
Operating AgreementThe governance document for an LLC - defines member rights, management structure, and profit distribution
EINEmployer Identification Number - the corporation’s tax ID, obtained from the IRS
Registered AgentA person or entity designated to receive legal documents on behalf of the corporation in its state of incorporation

Platform Terms

TermDefinition
CreditsPlatform service currency. 1 credit = $1. Used to pay for additional services. Subscription includes a credit allowance; additional credits can be purchased in packs
Client Setup AgreementThe service agreement between you and Talcott Forge for ROBS setup, reviewed and accepted before payment
Document LibraryYour dashboard’s document section where all generated and signed documents are stored and downloadable
Electronic SignatureDocuments requiring your signature are sent through our integrated e-signature platform and signed directly from your dashboard

Case Law

CaseWhat It Decided
Ellis v. Commissioner (2015)Self-directed compensation without governance controls is a prohibited transaction. Salary itself is not prohibited - unchecked self-dealing is
Peek v. Commissioner (2013)Personal guarantees on business debt are an indirect extension of credit to the plan - a prohibited transaction that disqualifies the entire plan
Swanson v. Commissioner (1996)A corporation without shares or shareholders doesn’t fit the definition of a disqualified person - relevant to the timing of stock purchases

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