Interest on a loan not treated as a distribution ( Q
4063) made, renewed, renegotiated, modified, or extended after December 31, 1986, is not deductible. No basis is created in a participant’s account with respect to nondeductible interest paid to a plan.
1 Interest paid on amounts borrowed under a retirement plan for the purchase or improvement of a principal residence is deductible as qualified residence interest if the loan is secured by a recorded deed of trust, is not the participant’s account balance,
2 and is deductible. Because custodial accounts and annuity carriers typically are unable to perfect a security interest, interest on these types of loans from 403(b) arrangements will not be deductible.
1. General Explanation of TRA ’86, p. 729.
2. Let. Ruls. 8935051, 8742025;
see also Earnshaw v. Comm., TC Memo 1995-156.