Regarding the holding period for NUA stock, see IRS Notice 98-24: <a rel="nofollow" target="_blank" href="
http://www.irs.gov/pub/irs-drop/not98-24.pdf">http://www.irs.gov/pub/irs-drop/not98-24.pdf</a>
For non-NUA stock, taxes will have been paid on the entire taxable amount of the distribution (usually the entire distribution), as if the stocks were sold by the qualified retirement plan and repurchased by the plan participant at that time, resetting the beginning of the holding period to the distribution date. (Also, the cost basis becomes the NAV on the date of distribution.) All appreciation will be appreciation that occurred after distribution. I've found numerous Private Letter Rulings where the IRS has stated that the holding period for the appreciation that occurs after distribution begins on the date of distribution, but I haven't found an IRS Notice or Rev Proc stating this.
Also, when stock is gifted, the holding period for that stock transfers to the recipient.
