Laurence Seymour

Laurence Seymour

Latham & Watkins LLP

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Proposed Section 409A Deferred Compensation Regulations Offer Helpful Clarifications of Current Rules

Treasury Department and IRS issue proposed regulations to address certain specific provisions of the existing Section 409A regulations. On June 21, 2016, the Department of the Treasury and the Internal Revenue Service...more

6/29/2016 - Comment Period Deferred Compensation IRS Proposed Regulation Section 409A Section 457A Stock Options Transaction-Based Compensation U.S. Treasury

Partnerships: IRS Extends Prohibition on Treating Partners as Employees

Employees of partnerships, LLCs or their disregarded entity subsidiaries who receive equity in such entities may be treated as “self-employed” for tax purposes. On May 3, 2016, the US Treasury Department (Treasury)...more

5/13/2016 - Comment Period Disregarded Entities Employee Benefits Employment Tax Income Taxes IRS Limited Liability Companies Proposed Regulation Self-Employment Tax U.S. Treasury

IRS Pursues 409A Audits, Issues Ruling on Certain Options/SARs under 457A

IRS audits signal focus on Section 409A compliance; Revenue Ruling makes certain nonqualified options and stock appreciation rights more attractive for offshore entities. The IRS has begun its limited audit initiative...more

7/8/2014 - Deferred Compensation IRS Offshore Companies Publicly-Traded Companies SAR Section 409A Shareholders Stock Options

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