Legal updates for: 409A


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New Proposed Treasury Regulations Focus on Management Fee Waivers

by Goodwin Procter LLP on

... July 22, 2015, the U.S. Treasury Department and Internal Revenue Service released proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code relating to disguised payments for services between partners and partnerships. The proposed regulations focus primarily on management fee waiver structures in investment funds, but also will... more






Alert: SEC Proposes Long-Awaited Compensation Clawback Rule

by Cooley LLP on

... July 1, 2015, the SEC issued a proposal to implement the last of the compensation-related provisions of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act that remained untouched on the SEC's plate—Section 954, the so-called "clawback" provision. The concept underlying the Dodd-Frank clawback provision is that a... more






SEC Proposes Broadened Executive Compensation “Clawback” Rules

by McGuireWoods LLP on

... July 1, the SEC proposed rules requiring national security exchanges (such as NYSE and Nasdaq) to establish listing standards requiring publicly traded companies to adopt, comply with and disclose written clawback policies. The proposed rules would implement Section 954 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act) and... more


The ERISA Litigation Newsletter - June 2015

by Proskauer Rose LLP on

...nges to the IRS determination letter program; an IRS Chief Counsel Memorandum clarifying the impact of correction of Section 409A failures; and recent case law on benefit claim exhaustion, ERISA stock drop claims in the Second Circuit, and the Third Circ... more




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