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SAR Internal Revenue Service

Amundsen Davis LLC

IRS Issues Final Section 162(m) Regulations On Companies’ Ability To Deduct Executive Pay

Amundsen Davis LLC on

The Internal Revenue Service (IRS) recently published final regulations implementing changes made by the Tax Cuts and Jobs Act of 2017 (TCJA) to Section 162(m) of the Internal Revenue Code (Section 162(m)) expanding the scope...more

King & Spalding

September and October 2015 Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

King & Spalding on

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties. To avoid such...more

Manatt, Phelps & Phillips, LLP

IRS Will Adopt “Common Sense” Approach To Structured Activity In Bank Accounts

Why it matters - In response to recent criticism, the Commissioner of the Internal Revenue Service (IRS) John A. Koskinen announced that the agency will adopt a “common sense” approach in how it handles funds that have...more

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

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

IRS Begins Section 409A Compliance Initiative

The Internal Revenue Service (IRS) is getting ready to ramp up enforcement of Section 409A of the Internal Revenue Code. The federal agency recently announced the launch of a new project to assess the level of taxpayer...more

Holland & Knight LLP

FinCEN Doubles Down on Casinos with Heightened Regulatory Expectations - Casino Managers and Tribal Gaming Commissioners Need to...

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For the second time in nine months, Financial Crimes Enforcement Network (FinCEN) Director Jennifer Shasky Calvery has publicly addressed FinCEN's increasing concerns regarding casino compliance with the Bank Secrecy Act...more

Proskauer - Employee Benefits & Executive...

IRS Issues Revenue Ruling on Applicability of Section 457A to Options and Stock Appreciation Rights

On June 10, 2014, the IRS issued Revenue Ruling 2014-18, which holds that nonqualified stock options, as well as stock-settled stock appreciation rights (SARs), do not constitute nonqualified deferred compensation subject to...more

K&L Gates LLP

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

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

Dechert LLP

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

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

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