News & Analysis as of

Offshore Companies Deferred Compensation

Dechert LLP

An Appreciation for Hedging Your Bets on Deferred Compensation

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

Latham & Watkins LLP

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

Latham & Watkins LLP on

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

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