While the news cycle in the world of sports is ever changing, a few occurrences in the past several years deserve further discussion in the executive compensation community – Shohei Ohtani’s deferral of $680 million in salary...more
When the IRS published proposed regulations harmonizing key provisions of Code Sections 409A and 457(f) in 2016, executive compensation lawyers and consultants rejoiced. It was not just that a long wait was over (roughly nine...more
The Internal Revenue Service ("IRS") recently notified a major university that it is being audited, and as part of that audit requested copies of the employment agreements of the president of the university, the provost of...more
Authors: John A. Morrison (Atlanta), Taylor Bracewell (Atlanta) Published Date: October 11, 2016 Earlier this summer, the Internal Revenue Service (IRS) issued proposed regulations under Sections 409A and 457 of the Internal...more
We're back with the second installment in our series on the IRS's Section 457 proposed rules. The first alert covered Section 457(f) basics and discussed the meaning of "deferred" compensation....more
On June 22, 2016, the Internal Revenue Service (IRS) published its long-awaited proposed regulations (the Proposed Regulations) under Section 457(f) of the Internal Revenue Code (the Code). Section 457(f) governs the taxation...more
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
There has been a lot of buzz recently about the long-awaited proposed rules issued by the Internal Revenue Service under Internal Revenue Code Section 457. Section 457 only applies to non-profit and governmental employers and...more
After more than nine years of waiting, eligible tax-exempt, state government and local government employers (collectively, "Tax-Exempt and Governmental Employers") finally have received the guidance long promised by the...more
The Internal Revenue Service recently released long anticipated proposed regulations (the “Proposed Regulations”) governing deferred compensation arrangements maintained by tax-exempt organizations and governmental entities...more
On the TV show Futurama, the aged proprietor of the delivery company Planet Express, Professor Hubert J. Farnsworth, had a habit of entering a room where the other characters were gathered and sharing his trademark line,...more
In June 2016, the IRS issued long-awaited proposed regulations under Section 457(f) of the Internal Revenue Code of 1986, as amended. While the proposed regulations will generally apply to compensation deferred under a plan...more
On June 21, 2016, after more than 15 years of ongoing deliberations, the U.S. Department of the Treasury (the Dept. of Treasury) issued proposed regulations under Section 457 of the Internal Revenue Code of 1986 (the Code),...more
On June 21, 2016, concurrent with its issuance of proposed regulations under Code section 409A, the IRS also issued proposed regulations under Code section 457, which address deferred compensation arrangements covering...more
On June 22, 2016, the Internal Revenue Service (IRS) and Treasury Department issued proposed regulations under Section 457 of the Internal Revenue Code, fulfilling a nearly decade-old commitment to provide additional...more
On the same day it released proposed regulations under Section 457 — as reported in our "New 457 Regulations for Nonqualified Deferred Compensation Plans of Tax-Exempt and Government Employers" update —the IRS released...more
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
The Treasury Department and the Internal Revenue Service recently issued comprehensive proposed regulations governing nonqualified plans subject to tax under Internal Revenue Code § 457. Code § 457 prescribes the tax rules...more
It took only 9 years since first announcing its intention to issue regulations, but the IRS has finally issued proposed regulations for deferred compensation arrangements sponsored by tax-exempt and governmental employers. ...more
The Internal Revenue Service recently issued proposed regulations under Section 457 of the Internal Revenue Code (the “Code”) that prescribe rules regarding deferred compensation plans sponsored by state and local governments...more
Section 409A - On June 22, 2016 the Internal Revenue Service issued new proposed regulations on the income inclusion provisions of Section 409A. These regulations will be of interest to employers that have nonqualified...more
On June 21, 2016, the Internal Revenue Service (IRS) issued long-awaited proposed Treasury Regulations prescribing rules under Section 457 of the Internal Revenue Code (the "Code") for the income taxation of deferred...more
Editor's Overview - In this month’s newsletter, our colleagues focus on two sets of legislative updates. First is a discussion of the IRS’s proposed Treasury Regulations prescribing rules under Section 457 of the...more
At long last, the IRS has released new proposed regulations under Internal Revenue Code section 457 – anticipated since 2007 — regarding nonqualified deferred compensation arrangements offered by tax-exempt organizations and...more
The Internal Revenue Service (IRS) on June 21, 2016, published long-awaited proposed rules on nonqualified deferred compensation plans under Section 409A of the Internal Revenue Code of 1986, as amended (Section 409A). These...more