Andrew C. Liazos

Andrew C. Liazos

McDermott Will & Emery

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Review of Section 409A Proposed Regulations

On June 22, 2016, the Internal Revenue Service (IRS) issued proposed changes to the regulations under the Internal Revenue Code (Code) §409A. The Code intends to clarify or modify a wide range of very restrictive rules...more

8/9/2016 - Corrections Death Benefits Deferred Compensation Exemptions Internal Revenue Code (IRC) IRS Proposed Regulation Safe Harbors Section 409A Stock Options Stocks Termination

A Blueprint for Maintaining an Individually Designed Qualified Plan after the IRS’s Determination Letter Program Cutback

In Depth - On June 29, 2016, the Internal Revenue Service (IRS) officially sounded the death knell for the five-year remedial amendment cycle with its release of Revenue Procedure 2016-37. Effective January 1, 2017,...more

7/14/2016 - Audits Benefit Plan Sponsors Determination Letter IRS Qualified Retirement Plans Retirement Plan Revenue Procedure 2016-37

IRS Provides New 409A Guidance; New Proposed Regulations Provide Additional Clarity, Warn of Abusive Practices, and Present...

In Depth - Additional flexibility to use Section 409A exemptions - ..Expanded availability of the rules for transaction-based compensation for stock rights and incentive stock options. The final regulations allow...more

6/24/2016 - Beneficiaries Debt Collection Deferred Compensation Employee Benefits Employee Stock Purchase Plans Employee Stock Purchase Rights Employment Contract Hiring & Firing IRS Safe Harbors Section 409A Severance Pay

IRS Issues Regulations Affecting Compensation Arrangements at Tax-Exempt Organizations

On June 21, the IRS issued long awaited proposed regulations under Section 457 of the Internal Revenue Code that affect a broad range of compensation arrangements at tax exempt organizations. If a compensation arrangement is...more

6/23/2016 - Compensation Agreements Deferred Compensation Employee Benefits Income Taxes Internal Revenue Code (IRC) IRS Non-Compete Agreements Severance Agreements Severance Pay Tax Exempt Entities Taxable Income Vesting

Section 162(m) Final Regulations Clarify Requirements for Exemptions to $1 Million Deduction Limitation

Section 162(m) generally limits to $1 million the amount that a public company can annually deduct with respect to remuneration paid to certain covered employees. This deduction limitation, however, does not apply to...more

4/6/2015 - Corporate Taxes Executive Compensation Final Rules IPO IRS Publicly-Traded Companies Stock Appreciation Rights Tax Deductions

IRS Ruling Allows Tax-Deferred Stock Rights for Fund Managers

Section 457A of the Internal Revenue Code (the Code) generally restricts the ability of offshore funds and other entities domiciled in tax-indifferent jurisdictions to offer tax-advantaged deferred compensation to U.S....more

6/24/2014 - Fund Managers Incentives IRS Stock Options Stocks

Camp Tax Reform Proposal Could Impact Executive Compensation

On February 26, 2014, U.S. House of Representatives Committee on Ways and Means Chairman Dave Camp (R-MI) released the proposed Tax Reform Act of 2014 (the Camp Proposal), which would simplify the Internal Revenue Code and...more

3/19/2014 - Corporate Taxes Deferred Compensation Executive Compensation IRS Tax Reform

IRS Issues Final Regulations Clarifying Substantial Risk of Forfeiture Under Section 83 of the Internal Revenue Code

The Internal Revenue Service (IRS) recently released new final regulations under Section 83 of the Internal Revenue Code (the Code) that confirm several positions that it has successfully taken in litigation about what is ...more

3/10/2014 - Forfeiture Internal Revenue Code (IRC) IRS

What You Need to Know About FATCA’s Impact on Non-U.S. Retirement Plans

The Internal Revenue Service recently published final regulations under the Foreign Account Tax Compliance Act (FATCA), which are effective immediately. FATCA imposes significant reporting obligations on both non-U.S....more

3/21/2013 - FATCA FFI Foreign Bank Accounts Intergovernmental Agreements IRS Reporting Requirements Retirement Plan Tax Penalties

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