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Additional “Cap A” guidance877Aaffects the treatment of deferred compensation

White & Case LLP
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USA
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November 18 2009

As of late, the "A" suffix has become synonymous with deferred compensationevident by sections 402A, 404A, 408A, 409A, 457A and, recently, 877A of the Internal Revenue Code

Expanded correction program for noncompliant nonqualified deferred compensation plans and arrangements

White & Case LLP
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USA
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July 21 2009

The Internal Revenue Service ("IRS") has issued Notice 2008-113 (the "Notice"), which expands the correction program for failures to operate nonqualified deferred compensation plans and arrangements in compliance with Section 409A of the Internal Revenue Code

Section 457A eliminates the ability of US taxpayers to defer compensation in offshore tax havens

White & Case LLP
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USA
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June 22 2009

On October 3, 2008, Section 457A was added to the Internal Revenue Code (the "Code") pursuant to the enactment of the Tax Extenders and Alternative Minimum Tax Relief Act of 2008

Request for IRS guidance on Section 162(m) and performance-based compensation plans: White & Case weighs in

White & Case LLP
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USA
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February 25 2008

A recent Private Letter Ruling reversing the IRS's position on the tax code's $1 million cap on exemptions for performance-based compensation could have created difficulties for companies making decisions about their 2008 executive compensation awards and proxy reporting on award deductibility

IRS narrows its views on "involuntary terminations" and performance-based compensation plans

White & Case LLP
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USA
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February 15 2008

In our last issue, we alerted you to published reports that the Internal Revenue Service (the "IRS") appears to have revised its thinking with respect to "performance-based compensation" plans under Section 162(m) of the Internal Revenue Code of 1986, as amended (the "Code"

IRS establishes limited correction program for certain operational failures under Section 409A

White & Case LLP
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USA
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January 15 2008

On December 3, 2007, the US Department of the Treasury and Internal Revenue Service (the “IRS”) issued Notice 2007-100, which announces a program allowing taxpayers to correct certain unintentional operational failures under Section 409A of the Internal Revenue Code

Has the IRS narrowed its views regarding “involuntary terminations” and performance-based compensation plans?

White & Case LLP
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USA
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January 15 2008

According to published reports, the Internal Revenue Service (the “IRS”) appears to have revised its thinking with respect to “performance-based compensation” plans under Section 162(m) of the Internal Revenue Code of 1986, as amended (the “Code”), which provide for payment of bonuses which are otherwise contingent on the satisfaction of certain performance goals in the event of involuntary terminations and retirement

New IRS notice: key information for Section 457 plan sponsors

White & Case LLP
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USA
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December 17 2007

The IRS has issued Notice 2007-62 (the “Notice”), regarding the interaction of Internal Revenue Code Section 457 plans and Internal Revenue Code Section 409A

Proposed law: the Offshore Deferred Compensation Reform Act of 2007

White & Case LLP
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USA
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November 12 2007

One of the key differences between nonqualified deferred compensation arrangements and qualified deferred compensation plans is that strict limits are imposed on the amount of compensation that can be deferred annually in a qualified plan (e.g., up to $15,000 or up to $20,500, including a $5,000 catch-up contribution for certain participants age 50 and older in a 401(k) plan and an additional $4,000 in an IRA) and the amount that a person (generally, highly-compensated) can defer in a nonqualified arrangement is generally unlimited

IRS updates determination letter procedures

White & Case LLP
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USA
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November 12 2007

On June 13, 2007, the Internal Revenue Service (the "IRS") issued Revenue Procedure 2007-44 ("Rev. Proc 2007-44"), which clarifies and expands guidance found in Revenue Procedure 2005-66, setting forth the current rules and procedures concerning determination letter submissions