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Gross up payments made with respect to golden parachute payments under Section 280G

  • Fox Rothschild LLP
  • -
  • USA
  • -
  • May 30 2010

Section 280G provides, in general, that the service provider receiving an excess parachute payment must incur a 20 nondeductible excise tax on the excess portion of the parachute payment which is usually associated with a payment triggered by virtue of "change of control" provision in an executive employment agreement