News & Analysis as of

Section 457A

Podcast - Shrink the Section 457A Tax on Hedge Fund Management and Incentive Fees and Expand Your Impact

by Ropes & Gray LLP on

In a recently released Ropes & Gray podcast, asset management partner Isabel Dische, tax partner Brett Robbins, and private client partner Cameron Casey discuss the effect of Section 457A on pre-2009 management and incentive...more

Looking over the edge of the Cliff - The Use of Pooled Income Funds to Reduce the Taxation of Offshore Repatriated Carried...

by Gerald Nowotny on

The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more

Cautionary Observations from the Proposed 457 Regulations

by Bryan Cave on

After more than nine years of deliberations, the IRS has finally released proposed regulations governing all types of deferred compensation plans maintained by non-profit organizations and governmental entities. In...more

IRS Issues Proposed Regulations Under Code Section 457

by Proskauer Rose LLP on

On June 21, 2016, the Internal Revenue Service (IRS) issued long-awaited proposed Treasury Regulations prescribing rules under Section 457 of the Internal Revenue Code (the "Code") for the income taxation of deferred...more

The ERISA Litigation Newsletter - June 2016

by Proskauer Rose LLP on

Editor's Overview - In this month’s newsletter, our colleagues focus on two sets of legislative updates. First is a discussion of the IRS’s proposed Treasury Regulations prescribing rules under Section 457 of the...more

IRS Issues Supplemental Guidance on Deferred Compensation Plans

by Holland & Knight LLP on

The Internal Revenue Service (IRS) on June 21, 2016, published long-awaited proposed rules on nonqualified deferred compensation plans under Section 409A of the Internal Revenue Code of 1986, as amended (Section 409A). These...more

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

by Latham & Watkins LLP on

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

IRS Proposed Tax Regulations Aimed at Fee Waiver Arrangements

by DLA Piper on

The Treasury Department and the Internal Revenue Service have issued proposed regulations addressing disguised payment for services of a partner, including the proper tax treatment of fee waiver arrangements commonly used by...more

Proposed IRS Regulations Target Management Fee Waiver Arrangements

by Bracewell LLP on

On July 22, 2015, the Treasury Department and the Internal Revenue Service (“IRS”) released proposed regulations (the “Proposed Regulations”) regarding disguised payments for services under Section 707(a)(2)(A) of the...more

An Appreciation for Hedging Your Bets on Deferred Compensation

by Dechert LLP on

Under Section 457A of the U.S. Internal Revenue Code of 1986 (the “Code”), certain offshore and other entities are limited in their ability to provide tax-effective deferred compensation to providers of services to those...more

Possible Offshore Deferrals for Hedge Fund Managers – IRS Confirms That Certain Stock Options and Stock Appreciation Rights Are...

by Proskauer Rose LLP on

The Internal Revenue Service (the "IRS") has issued Revenue Ruling 2014-18 (the "Ruling"), which generally confirms that a stock-settled stock option or stock appreciation right that is granted with an exercise/base price of...more

New IRS Revenue Ruling 2014-18 and the Use of Hedge Fund Stock Options

by K&L Gates LLP on

The Internal Revenue Service has issued Revenue Ruling 2014-18 (the “Ruling”) to clarify that stock options and stock-settled stock appreciation rights (“SARs”), properly designed, can be used as a form of compensation to...more

An Appreciation for Hedging Your Bets on Deferred Compensation: IRS Issues Revenue Ruling 2014-18 Under Section 457A of the...

by Dechert LLP on

Under Section 457A of the Internal Revenue Code of 1986 (the “Code”), certain offshore and other entities are limited in their ability to provide tax-effective deferred compensation to providers of services to those entities....more

Another Unexpected Surprise for International Assignees: Section 457A (No, Not 409A!) of the U.S. Tax Code

by Littler on

By now, most lawyers advising international companies on compensation packages for expatriates that include deferred compensation are familiar with section 409A of the United States Internal Revenue Code (“US tax code” or...more

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