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Internal Revenue Code (IRC) Deferred Compensation Income Taxes

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

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

McDermott Will & Emery

Weekly IRS Roundup November 4 – November 8, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 4, 2024 – November 8, 2024...more

Lowenstein Sandler LLP

Deferred Compensation: A Primer on Section 409A of the Code and Why it Matters

Lowenstein Sandler LLP on

On this episode of “Just Compensation,” the hosts provide an introduction into Section 409A, the complicated tax code provision that governs non-qualified deferred compensation: when does it apply, how do you comply with it,...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

Snell & Wilmer

Short-Term Deferral Day is Right Around the Corner

Snell & Wilmer on

Section 409A, the provision of the Internal Revenue Code that regulates the time and form of payment of nonqualified deferred compensation, contains a helpful exception for “short-term deferrals.” Specifically, Section 409A...more

Holland & Hart - The Benefits Dial

Our D.I.V.O.R.C.E. … Is Going To Be Tricky For My Employer To Handle

Nonqualified deferred compensation plans often include anti-assignment language prohibiting a plan participant from assigning benefits to anyone. Because top-hat plans are exempt from most aspects of ERISA including the...more

Groom Law Group, Chartered

Possible Options for Participant Relief Under Section 409A Plans in the Time of Coronavirus

The coronavirus pandemic has caused widespread economic uncertainty and unanticipated liquidity issues for a wide range of individuals, including plan participants of nonqualified deferred compensation plans. In these...more

McDermott Will & Emery

More IRS “Campaigns?! IRS Announces Six More Examination Campaigns

McDermott Will & Emery on

On July 19, 2019, the Internal Revenue Service (IRS) Large Business & International (LB&I) division announced the approval of six new campaigns. As in the past, the IRS stated that “LB&I’s goal is to improve return selection,...more

Rosenberg Martin Greenberg LLP

Final Section 199A Regulations: Interpretation of W-2 Wages and UBIA Thresholds May Significantly Limit the QBI Deduction

When it was announced that the Tax Cuts and Jobs Act included a new 20% deduction for qualified business income (“QBI”) of pass-through businesses, many business owners started planning for huge tax savings. Hopefully, their...more

Holland & Knight LLP

Seven Tips for Tribal Governments to Reduce Tribal Member Taxes in 2019

Holland & Knight LLP on

• With Democrats taking control of the U.S. House of Representatives, tax provisions affecting tribal governments and their members are once again on the table for discussion. • This notice provides an overview of seven...more

Katten Muchin Rosenman LLP

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

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

Snell & Wilmer

Short-Term Deferral Day is Right Around the Corner

Snell & Wilmer on

Section 409A, the provision of the Internal Revenue Code that regulates the time and form of payment of nonqualified deferred compensation, contains a helpful exception for “short-term deferrals.” Specifically, Section 409A...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part VI: Employment and Fringe Benefit Related Provisions

Foster Garvey PC on

BACKGROUND - The Tax Cuts and Jobs Act (“TCJA”) creates, modifies or eliminates a number of employment and employee fringe benefit related provisions of the Code. Both employers and employees need to be aware of these...more

Ballard Spahr LLP

Federal Tax Reform: The Senate Bill – Comparison to the House Bill, and Evaluating the Bigger Picture

Ballard Spahr LLP on

The Senate Finance Committee released a detailed description of the Senate's tax reform bill, titled the Tax Cuts and Jobs Act, on November 9. The Committee has not released the text of the bill, and likely will not do so...more

Sheppard Mullin Richter & Hampton LLP

Thanksgiving Tax Frenzy – New Tax Bill Proposes Executive Compensation Changes That Could Derail Deferred Compensation and Stock...

Congress has been in a frenzy to try and get new tax legislation passed by Thanksgiving, and members of the House and Senate would presumably rather be enjoying a feast rather than drafting and analyzing additional tax...more

Akin Gump Strauss Hauer & Feld LLP

Tax Cuts and Jobs Act

On November 2, 2017, the Committee on Ways and Means of the U.S. House of Representatives released its tax reform bill titled the Tax Cuts and Jobs Act (the “House Bill”). On November 6, 2017, Kevin Brady, Chairman of the...more

Katten Muchin Rosenman LLP

House Bill Proposes Major Modifications To Employee Compensation And Benefits-Related Laws; Initial Amendments Provide Limited...

The Tax Cuts and Jobs Act proposed by the US House of Representatives on November 2 (House Bill) proposes major modifications to employee and partner compensation and benefits-related provisions of the Internal Revenue Code,...more

A&O Shearman

The Republican Tax Plan and the Revenue-Raising Assault on Employee Compensation

A&O Shearman on

On November 2, 2017, the Republican caucus of the House of Representatives unveiled its plan to overhaul the nation’s tax code. In an apparent effort to raise revenue, the “Tax Cuts and Jobs Act,” if adopted, would...more

Polsinelli

UPDATE: Three Significant Takeaways from the Tax Cuts and Jobs Act

Polsinelli on

This update to our Tax Alert on Nov. 2nd describes additional key provisions in the “Tax Cuts and Jobs Act” (H.R. 1), released by the Chairman of the House Ways and Means Committee on Nov. 2nd, as well as the Chairman’s...more

Katten Muchin Rosenman LLP

2016 Year-End Estate Planning Advisory

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

Parker Poe Adams & Bernstein LLP

New IRS Guidance on Deferred Compensation for Tax-Exempt and Governmental Employers

Tax-exempt and governmental employers do not pay Federal income tax and therefore, unlike for-profit entities, are not affected by the timing of tax deductions relating to the payment of compensation. Tax authorities are...more

Katten Muchin Rosenman LLP

Proposed Treasury Regulations Provide Additional Flexibility, Clarity and Planning Opportunities to Sponsors of Deferred...

The IRS recently issued proposed regulations under Internal Revenue Code Section 457 that address, among other things, the interplay between Code Section 457(f) and Code Section 409A. Additionally, the IRS issued clarifying...more

Proskauer - Tax Talks

Proposed Section 409A Regulations Would Clarify Separation from Service Analysis in Connection with Change in Status From Employee...

Proskauer - Tax Talks on

Pursuant to the final regulations under Section 409A of the Internal Revenue Code of 1986, as amended, a termination of employment generally occurs at such time as the employer and employee reasonably anticipate that the...more

Proskauer - Tax Talks

IRS Releases Proposed Regulations To Clarify Section 409A Provisions

Proskauer - Tax Talks on

The Internal Revenue Service (IRS) recently issued proposed Treasury Regulations that would clarify certain provisions of the final regulations under Section 409A of the Internal Revenue Code of 1986, as amended (the “Code”)....more

Eversheds Sutherland (US) LLP

Deferred No Longer: Treasury and IRS Issue Long-Awaited 409A Guidance

On June 21, the Treasury Department and the Internal Revenue Service (IRS) issued proposed Internal Revenue Code (Code) section 409A regulations, modifying existing proposed and final section 409A regulations regarding...more

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