RISKS AND UNCERTAINTIES
The Plan, through the Master Trust, holds various investment securities. Investment securities are exposed to various risks such as interest rate, market and credit risks. Due to the level of risk associated with certain investment securities, it is at least reasonably possible that changes in the values of investment securities will occur in the short term and that such changes could materially affect participants ?? account balances and amounts shown in the statement of net assets available for benefits.
PARTY OF INTEREST
The Plan, through the Master Trust, invests in Berkshire Hathaway Class B Shares within the Berkshire Hathaway Class B Equity Fund. The following activity is presented at the master trust level: during the years ended December 31, 2020 and 2019, 64,603 and 27,765 Class B shares, respectively, of Berkshire Hathaway at a cost of $ 12,604,948 and 5,604 $ 251 respectively, were purchased within the fund. All the shares purchased were acquired at the market value then in effect on the open market. In addition, during the years ended December 31, 2020 and 2019, the fund sold or distributed to participants 94,317 and 97,870 Class B shares, respectively, of Berkshire Hathaway and received proceeds of $ 19,329,580 and $ 20,377,139, respectively. Gains realized on these sales were $ 4,169,251 and $ 5,206,235 for 2020 and 2019, respectively.
The Plan obtained its last Letter of Determination dated September 28, 2017, in which the Internal Revenue Service declared that the Plan, as then designed, complied with the applicable requirements of Section 401 of the Internal Revenue Code. The Plan has been amended since the receipt of this letter of determination. However, the Company believes that the Plan is currently designed and operated in accordance with the applicable requirements of the Internal Revenue Code. Consequently, no provision for income taxes has been included in the financial statements of the Plan.
The plan administrator analyzed the tax positions taken by the plan and concluded that as of December 31, 2020, no uncertain position taken or anticipated would require such recognition or disclosure in the financial statements.
The Plan was adopted in the hope that it will continue indefinitely. The Company may, however, terminate the Plan at any time. In addition, the management of any branch can remove that branch from the plan at any time. Upon termination of the plan, all participants will immediately become fully vested at the value of their account balances.
Physical and economic conditions around the world have been affected by the COVID-19[female[feminine
pandemic. Uncertainties surround COVID-19 ?? s impact on the economy as a whole, on businesses and on the investment market. There is also uncertainty about the positive impact of any federal relief effort up to the date of this report. Therefore, the impact of the global pandemic on the current and future operations of the Company or the Plan is unknown.
All Plan investments are held by Voya Institutional Trust Company in participant-driven investment funds and the Plan’s registrar is Voya Institutional Plan Services. All investments have been transferred in nature to Great-West Trust Company, LLC and Empower Retirement, LLC, who became the new Trustees and Registrars, respectively, effective January 4, 2021.