Can the cancellation of a stock option be considered a deferral of compensation under Section 409A?

Jun 6, 2017 ... The attached article briefly describes the applicable law and available guidance, illustrates the issue in an example, and provides two plausible analyses. Aug 9, 2007 ... This Insight discusses how Section 409A affects employment agreements, severance arrangements and settlement agreements. Under Section 409A, deferral elections must be made by the end of the taxable year before the year in which deferrals are made. Companies generally hold open ... Section 409A allows participants to delay the distribution or change the form of the benefit of scheduled distributions as long as outlined rules are followed. Jul 1, 2016 ... Section 409A generally provides that if a non-qualified deferred compensation arrangement fails to satisfy the applicable requirements of ... Inclusion In Gross Income Of Deferred Compensation Under Nonqualified Deferred Compensation Plans. I.R.C. § 409A(a) Rules Relating To Constructive Receipt. Sep 13, 2007 ... Six-Month Delay for Separation Payments to Key Employees: The requirement to express a six-month delay for certain separation payments to key ... Feb 17, 2021 ... The 409A regulations are complicated comprising hundreds of pages. Employers and executives should consult competent tax counsel before entering ... Aug 11, 2010 ... Six years after its enactment in 2004, section 409A of the Internal Revenue Code, 26 U.S.C. § 409A, has developed to be almost everything a ... Jul 12, 2023 ... In this context, the punitive tax result is exacerbated by the fact that the employee did not receive any cash. Further, section 409A requires a ...