A bank sponsors a profit sharing plan. The plan has invested a portion of its assets in participation interests in loans made by the bank. In other words, the bank makes a loan to a third party, and then sells all or a portion of the note to the plan. This appears to be a prohibited transaction (sale or exchange of property) for which there is no exemption.
How is the excise tax calculated? Would the "amount involved" be the amount paid by the plan for the note? Is there a 15% excise tax liability for every year the plan holds the note, or is it just a one-time excise tax for the year in which the note was purchased?