How does Section 409A affect split-dollar arrangements other than life insurance?

Feb 11, 2025 ... Description. A nonqualified deferred compensation plan is a plan that provides a legally binding right in one taxable year to compensation that ... Section 409A governs the federal tax treatment of a wide variety of NQDC arrangements, which are generally defined as any legally binding compensation ... May 13, 2015 ... IRS Chief Counsel Memorandum Clarifies that Correction of Section 409A Failures in Year of Vesting Will Not Shield Income Inclusion Under 409A. Dec 4, 2013 ... Regardless, if the reimbursement constitutes taxable income for the employee and is subject to Section 409A of the Internal Revenue Code (the “ ... Section 409A of the United States Internal Revenue Code is a complex and often counterintuitive set of tax rules applicable to non-qualified deferred ... Inclusion In Gross Income Of Deferred Compensation Under Nonqualified Deferred Compensation Plans. I.R.C. § 409A(a) Rules Relating To Constructive Receipt. appreciates this opportunity to comment on certain discrete portions of the Proposed Regulations under Section. 409A of the Internal Revenue Code (“Section ... Jun 26, 2010 ... This article provides an overview of some key aspects of Section 409A, the $1 million limit under Section 162(m), and the golden parachute rules ... No person shall, in any city or town of this state, engage in or carry on the business of loaning money upon deposits or pledges of fine art unless such person ... The Department of Treasury and Internal Revenue Service (IRS) today released final regulations implement Section 409A of the Tax Code governing deferrals of ...