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The first IRS letter approving this sort of trust involved a Rabbi, hence the name Rabbi Trust. The employer's contribution to the trust is tax-deductible, and the employee does not have to pay tax on that sum until he/she receives it from the trust.
The Rabbi trust allows the deferment of compensation whether employment income or the purchase price of a business acquisition, and the absence of this would result in the taxability to the payee of the compensation not yet received by the payee. This would serve as a disincentive for deferring such payments.
How Do You Establish a Rabbi Trust? You as settler or grantor establish a rabbi trust by entering into a trust agreement with a trustee (usually a bank or trust company). The trustee then holds the NQDC plan contributions and investment earnings. A single rabbi trust can benefit more than one employee.
The Disadvantage of Rabbi Trusts If the founding company declares bankruptcy or otherwise becomes insolvent, its creditors will have unbridled access to the rabbi trust's funds?potentially depriving employees of their own earnings.