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Deferred compensation for executives under sec. 409A.(part 2)
Tax Adviser, The, August, 2006 by Singer, Stuart R.
EXECUTIVE SUMMARY
* Virtually all stock option arrangements are potentially regulated by Sec. 409A.
* Sec. 409A provides an exclusive list of permitted distributions; everything else is prohibited.
* The Service has blanket authority to determine permitted accelerated distributions.
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This two-part article discusses how Sec. 409A and the current proposed regulations apply to deferred compensation arrangements. Part II covers the applicability of Sec. 409A to equity-based compensation arrangements, permitted distributions and the election to defer compensation.
Sec. 409A and the current proposed regulations impose a new set of roles for taxation of deferred compensation. Part I of this two-part article,...
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