How does an IPO impact the valuation of deferred compensation arrangements?

2 Section 409A imposes a significant tax penalty on deferred compensation arrangements that do not meet its numerous technical requirements.3 Thus, the effect ... 26 U.S. Code § 409A - Inclusion in gross income of deferred compensation under nonqualified deferred compensation plans · (A). at the time set aside if such ... Section 409A of the United States Internal Revenue Code is a complex and often counterintuitive set of tax rules applicable to non-qualified deferred ... Aug 9, 2007 ... This Insight discusses how Section 409A affects employment agreements, severance arrangements and settlement agreements. Nov 30, 2007 ... Code section 409A applies to many arrangements not traditionally considered “deferred compensation.” This article reviews Code section 409A issues as they ... Mar 17, 2022 ... Federal taxation of deferred compensation is complex! Listen to this practice video on the topic by Morrison Cohen partner, Alan Levine to ... This article examines the scope of Section 409A and Notice 2010-6 and details the applicability of both to hedge funds and hedge fund managers. Jul 1, 2016 ... Section 409A generally provides that if a non-qualified deferred compensation arrangement fails to satisfy the applicable requirements of ... May 6, 2024 ... The section 409A regulations implemented the concept in a detailed rule called the “independent contractor exception,” which expressly exempts ... Jun 22, 2016 ... This document contains proposed regulations that would clarify or modify certain specific provisions of the final regulations under section 409A.