Searching Content indexed under Tax by Andrew Liazos ordered by Published Date Descending.
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IRS Issues Long-Awaited Initial Guidance Under Section 162(m)
On August 21, 2018, the IRS issued guidance regarding recent statutory changes made to Section 162(m) of the Internal Revenue Code.
United States
30 Aug 2018
Impacts On 162(m) (Video)
Andrew Liazos and David Fuller identify the three main areas to focus on in light of 162(m) and discuss traps for the unwary.
United States
4 Jun 2018
District Court Dismisses Shareholder Claim That Equity Award Share Withholding Triggers Section 16(b) Liability
While an encouraging development, this decision is now on appeal to the US Court of Appeals for the Fifth Circuit and there are similar unresolved complaints in other jurisdictions.
United States
22 Jun 2017
Proposed Changes To 409A Regulations Provide Greater Clarity And Planning Alternatives
On June 22, 2016, the Internal Revenue Service (IRS) issued proposed regulations to modify and clarify existing regulations under Section 409A of the Internal Revenue Code.
United States
5 Jan 2017
Maintaining Retirement Plan Documents After Revenue Procedure 2016-37
At the 2016 Joint Fall CLE Meeting on October 1, 2016, Andrew Liazos presented on "Maintaining Retirement Plan Documents after Revenue Procedure 2016-37."
United States
20 Oct 2016
Review Of Section 409A Proposed Regulations
The following PowerPoint highlights key points from the proposed regulations and what employers and employees should know and can expect moving forward.
United States
11 Aug 2016
A Blueprint For Maintaining An Individually Designed Qualified Plan After The IRS's Determination Letter Program Cutback
On June 29, 2016, the Internal Revenue Service (IRS) officially sounded the death knell for the five-year remedial amendment cycle with its release of Revenue Procedure 2016-37.
United States
19 Jul 2016
IRS Provides New 409A Guidance: New Proposed Regulations Provide Additional Clarity, Warn Of Abusive Practices And Present Planning Opportunities
On June 21, 2016 the IRS issued proposed regulations to modify and clarify existing regulations under Section 409A of the Internal Revenue Code.
United States
27 Jun 2016
IRS Issues Regulations Affecting Compensation Arrangements At Tax-Exempt Organizations
There have been questions as to whether vesting conditions imposed after a compensation arrangement has been established will be respected for tax purposes.
United States
23 Jun 2016
Special Executive Compensation Tax Issues In Corporate Transactions
In the corporate transactions context, it is increasingly important to be familiar with the key tax considerations relating to mergers and acquisitions, and how to minimize tax risks in such transactions.
United States
4 Apr 2016
Section 162(m) Final Regulations Clarify Requirements For Exemptions To $1 Million Deduction Limitation
Section 162(m) generally limits to $1 million the amount that a public company can annually deduct with respect to remuneration paid to certain covered employees.
United States
8 Apr 2015
Camp Tax Reform Proposal Targets Executive Compensation
On February 26, 2014, US House of Representatives Committee on Ways and Means Chairman Dave Camp (R-Mich.) released the proposed Tax Reform Act of 2014.
United States
6 Aug 2014
IRS Releases Final Instruction For Form W-8BEN-E
In March 2013, the IRS issued the final version of Form W-8BEN-E Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding and Reporting.
United States
30 Jun 2014
IRS Ruling Allows Tax-Deferred Stock Rights For Fund Managers
The IRC restricts the ability of offshore funds domiciled in tax-indifferent jurisdictions to offer tax-advantaged deferred compensation to U.S. persons.
United States
25 Jun 2014
Non-U.S. Retirement Plans Must Comply With Or Claim Exemption From FATCA By July 1
FATCA is intended to make it more difficult for U.S. taxpayers to conceal assets held in offshore accounts.
United States
13 Jun 2014
Camp Tax Reform Proposal Could Impact Executive Compensation
House of Representatives Committee on Ways and Means Chairman Dave Camp released the proposed Tax Reform Act of 2014.
United States
20 Mar 2014
IRS Issues Final Regulations Clarifying Substantial Risk Of Forfeiture Under Section 83 Of The Internal Revenue Code
The Internal Revenue Service (IRS) recently released new final regulations under Section 83 of the Internal Revenue Code (the Code) that confirm several positions that it has successfully taken in litigation about what is a substantial risk of forfeiture (SRF) under Section 83 of the Code.
United States
8 Mar 2014
April 15th Deadline For Filing FICA Refunds For Severance Pay
Severance pay due to an involuntary separation from employment resulting from a reduction in force, plant shutdown or similar condition may be exempt from FICA taxes.
United States
23 Jan 2013
Public Company Priorities For The New Year
Looking ahead to 2013, directors, executives and general counsel of public companies can take some solace from the fact that 2012 was not a year in which a large number of significant new disclosure rules or governance requirements were adopted by the SEC or the stock exchanges as had regularly been the case in the prior 10 years.
United States
31 Dec 2012
Recent Case Suggests How Private Equity Funds Can Protect Against Unfunded Pension Liabilities Of Portfolio Companies
A recent decision by the U.S. District Court of Massachusetts specifically rejects the 2007 Pension Benefit Guaranty Corporation opinion.
United States
13 Nov 2012
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