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Golden Parachutes › Internal Revenue Service

Golden Parachute is a term used to describe agreements between companies and employees (usually high-level executives) whereby employees are significantly compensated in the event employment is terminated.... more +
Golden Parachute is a term used to describe agreements between companies and employees (usually high-level executives) whereby employees are significantly compensated in the event employment is terminated. Typically, Golden Parachutes are implicated in the event of a merger or take-over of the original company and take the form of stock options, severance payments, and/or bonuses.  less -
Proskauer - Employee Benefits & Executive...

Stranger in a Strange Land: Surprising Applications of U.S. Golden Parachute Rules in Cross-Border Transactions

Proskauer - Employee Benefits & Executive... on

Background - The “golden parachute” excise tax regime under Internal Revenue Code Sections 280G and 4999 (“Section 280G” and “Section 4999”, respectively) is at the core of both public and private U.S.-based transactions....more

Holland & Hart - The Benefits Dial

Free Fallin’…With a Golden Parachute

Holland & Hart - The Benefits Dial on

For those who have been involved in the sale of a company, Section 280G of the Internal Revenue Code may sound familiar. Section 280G governs what the IRS considers to be “golden parachute payments” and is generally...more

Foley & Lardner LLP

Form and Substance: Why the Form of a Transaction is so Critical to Employee Benefits and Executive Compensation Strategy

Foley & Lardner LLP on

The form of a corporate transaction sets the stage for the employee benefits and executive compensation (EBEC) strategy – in the scope of due diligence and purchase agreement negotiations and post-closing activity. The charts...more

Mintz Edge

Management Carve-Out Plans

Mintz Edge on

A company may find itself in a position to sell for a variety of reasons: a sale may be necessary to continue its growth, a potential buyer made an offer too good to pass up, or the owners are simply looking towards their...more

Morgan Lewis

IRS Releases Proposed Regulations on Executive Compensation for Tax-Exempt Organizations

Morgan Lewis on

The Internal Revenue Service and US Department of the Treasury have released proposed regulations governing the excise tax imposed by Internal Revenue Code Section 4960 on certain executive compensation paid to employees of...more

Seyfarth Shaw LLP

Executive Compensation at Tax-Exempt Organizations Back in the Limelight – IRS Issues New Guidance

Seyfarth Shaw LLP on

Seyfarth Synopsis: The IRS recently issued proposed regulations providing guidance under Internal Revenue Code (“Code”) Section 4960, which provides for an excise tax on tax-exempt organizations that pay certain executives in...more

Cozen O'Connor

IRS Issues Proposed Regulations for Tax on Nonprofit Executive Compensation

Cozen O'Connor on

The Internal Revenue Service has issued proposed regulations describing the rules regarding the 21 percent excise tax on compensation over $1 million and excess parachute payments paid by tax-exempt organizations to certain...more

Verrill

IRS Guidance Regarding the Section 4960 Excise Tax Is (Somewhat) Helpful

Verrill on

IRS Notice 2019-09 provides guidance intended to help “applicable tax-exempt employers” determine whether compensation paid to their most highly compensated employees will be subject to the 21 percent excise tax imposed under...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

IRS Notice Offers Good News for State Colleges and Universities (at Least for Now)

Ogletree, Deakins, Nash, Smoak & Stewart,... on

In January 2019, the Internal Revenue Service (IRS) issued Notice 2019-09, which provides interim guidance for Section 4960 of the Internal Revenue Code of 1986. As a reminder, Section 4960 imposes an excise tax of 21 percent...more

Holland & Knight LLP

IRS Notice Provides Guidance for Exempt Organizations on Excise Tax

Holland & Knight LLP on

• The Internal Revenue Service (IRS) released IRS Notice 2019-09 (Notice) offering guidance under Section 4960 of the Internal Revenue Code as added by the Tax Cuts and Jobs Act. • Section 4960 applies to certain...more

Katten Muchin Rosenman LLP

Interim IRS Guidance on New Executive Compensation Requirements for Tax-Exempt Entities Creates New Challenges

Katten Muchin Rosenman LLP on

Under new Section 4960 ("Section 4960") of the Internal Revenue Code of 1986, as amended ("IRC") that was adopted as part of the Tax Cuts and Jobs Act of 2017 (Tax Act), an excise tax under IRC Section 11 (currently 21...more

Eversheds Sutherland (US) LLP

Treasury and IRS issue interim guidance on executive compensation excise tax under section 4960

Eversheds Sutherland (US) LLP on

On December 31, 2018, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) issued Notice 2019-09 (Notice) providing comprehensive interim guidance under section 4960 of the Internal...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Don’t Forget About Section 4960 Compliance

Ogletree, Deakins, Nash, Smoak & Stewart,... on

Section 4960 of the Internal Revenue Code of 1986 (IRC), as amended, imposes an excise tax on compensation of certain highly compensated employees of tax-exempt organizations. In an apparent attempt to level the playing field...more

McDermott Will & Emery

Internal Revenue Service Updates Golden Parachute Payments Audit Technique Guide, Signaling Key Items IRS May Review on Audit

McDermott Will & Emery on

In early 2017, the IRS updated its Golden Parachute Payments Audit Technique Guide for the first time since its 2005 issuance. While intended as an internal reference for IRS agents conducting golden parachute examinations,...more

Orrick, Herrington & Sutcliffe LLP

IRS Updates Golden Parachute Audit Guide

Orrick, Herrington & Sutcliffe LLP on

This is our first of many alerts during 2017 as the new administration signals the rollback of many regulations (e.g., fiduciary rules and pay ratio). We will keep you posted. In January 2017, the Internal Revenue...more

Smith Anderson

Golden Parachute Tax Terror

Smith Anderson on

Smith Anderson's tax group is now offering complimentary presentations. This webinar will provide an introduction to the tax rules related to certain payments to insiders triggered by a change in control of a corporation...more

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