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Deferred Compensation › Tax Liability

Deferred Compensation is a financial arrangement whereby a portion of an employee's current wages are distributed at a later time, usually to delay tax liability. Deferred compensation often takes the form of... more +
Deferred Compensation is a financial arrangement whereby a portion of an employee's current wages are distributed at a later time, usually to delay tax liability. Deferred compensation often takes the form of stock options or severance payments.  less -
Offit Kurman

Unexpected Tax Penalties in Talent Contracts: Could Your Motion Picture, Recording, or Sports Contract be Subject to IRC Section...

Offit Kurman on

Could your motion picture agreement, recording agreement, or sports contract be a non-qualified deferred compensation arrangement? You may think it unlikely, but a non-qualified deferred compensation arrangement refers to any...more

Fleurinord Law PLLC

Shohei Ohtani’s $700M Tax Deferral Strategy: What High-Income Earners Must Know

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Let’s be real—when you hear someone landed a $700 million deal, your first thought probably isn’t taxes. But Shohei Ohtani’s record-breaking contract with the Los Angeles Dodgers has become ground zero in a growing tax policy...more

Gerald Nowotny - Law Office of Gerald R....

Still the One! – The Use of Private Placement Life Insurance in Tax Planning for Trial Attorneys with Contingency Fee Income

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In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more

Pullman & Comley - Labor, Employment and...

Retirement Plans: Will January 1, 2024 Effective Date for Age 50 Catch-Up Contribution Changes Be Delayed?

Pullman & Comley - Labor, Employment and... on

Section 401(k) Plans, Section 403(b) Plans and governmental Section 457(b) Plans generally permit employees to defer compensation on a pre-tax basis. These plans may also provide the opportunity for employees to defer...more

Williams Mullen

Hoops, LP: Seventh Circuit Denies Deferred Compensation Deduction in Taxable Asset Sale - Upsetting Common Understanding of Timing...

Williams Mullen on

On August 9, 2023, the Seventh Circuit Court of Appeals in Hoops, LP and Heisley Member, Inc., Tax Matters Partner vs. Commissioner of Internal Revenue, affirmed the Tax Court’s 2022 decision denying a deduction to a plan...more

Rivkin Radler LLP

Tax Court’s Decision On Assumption of Liability in M&A – A Clean Block or Goaltending?

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Assumed Liabilities- If a taxpayer were to sell the assets that comprise the taxpayer’s business, they would realize gain if the amount realized by the taxpayer from the sale is more than the taxpayer’s adjusted basis for...more

Freeman Law

Tax Court in Brief | Hoops, LP v. Commissioner: Deductibility of Deferred Compensation

Freeman Law on

Tax Litigation: The Week of February 21, 2022, through February 25, 2022 - Hicks v. Comm’r, T.C. Memo. 2022-10 | February 23, 2022 | Gale, J. | Dkt. No. 10406-17 - Hoops, LP v. Comm’r, T.C. Memo. 2022-9 | February 23,...more

Carlton Fields

Retirement Plans Can Solve The Million-Dollar Problem For Entities At Risk Of Excise Taxes On Compensation

Carlton Fields on

All entities, including governmental entities, are now potentially liable for penalties due to overpaying employees....more

Holland & Knight LLP

A Tribal Financial Executive’s Guide to Deferred Per Capita Plans

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With the top tax bracket at nearly 40 percent, Indian tribes making substantial per capita distributions are asking what they can do to reduce their members’ tax liabilities. One option to consider is a deferred per capita...more

Jackson Walker

Davidson v. Henkel — What’s Going On With Nonqualified Deferred Compensation Plans and FICA

Jackson Walker on

In This Presentation: - Davidson v. Henkel Corp. - The Parties - NQ Plan - The Plan’s Tax Clauses - Davidson’s Pre-Retirement Counseling - 2011 Compliance Review and Letter - Henkel’s Tax...more

Stinson - Benefits Notes Blog

Nonresident Employee Avoids New York Taxes On Deferred Compensation Payment

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A taxpayer we will call John worked for a savings bank in New York that was acquired by Washington Mutual Bank. John participated in the New York bank’s supplemental executive retirement plan (SERP) and its deferred...more

Saul Ewing Arnstein & Lehr LLP

Court Of Federal Claims Upholds 409A "Gotcha"

Saul Ewing Arnstein & Lehr LLP on

If your company has been cavalier about Internal Revenue Code Section 409A, you should reconsider. In a recent opinion by the United States Court of Federal Claims, the IRS scored the first points – more than $5 million of...more

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