Who is liable for the taxes imposed by Section 409A?

Severance payments made under a window program (i.e., a program in which employees are offered enhanced benefits if they voluntarily terminate employment during ... Feb 17, 2021 ... The 409A regulations are complicated comprising hundreds of pages. Employers and executives should consult competent tax counsel before entering ... 99–514, as amended, set out as a note under section 401 of this title. §409A. Inclusion in gross income of deferred compensation under nonqualified deferred. Apr 5, 2017 ... Up to 2x lesser of: • Employee's 409A “annualized compensation”. • Code Section 401(a)(17) limit - $270,000 for 2017. 9. Page 10. The Section ... The Department of Treasury and Internal Revenue Service (IRS) today released final regulations implement Section 409A of the Tax Code governing deferrals of ... Section 409A can apply to nonqualified retirement plans, elective deferrals of compensation, severance and separation programs, post- employment payments ... Not only are traditional nonqualified deferred compensation plans such as supplemental executive retirement plans affected, Section. 409A also governs many ... Feb 11, 2025 ... He also regularly provides tax planning advice with respect to Internal Revenue Code Sections 409A and 162(m), as well as the excise tax on “ ... Jan 8, 2008 ... Background. Section 409A principally regulates timing with re- spect to nonqualified deferred compensation — timing in regard to elections to ... Sep 3, 2013 ... The regulations under Section 409A give us two possible safe harbors for private companies which, if complied with, will give us the presumption that our ...