Searching Content indexed under Tax Authorities 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
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
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
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
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
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
Beware This Threat To Exec-Comp Tax Deductions
An IRS compensation rule aimed at health insurers could actually apply to a wide range of companies.
United States
3 Sep 2012
IRS Permits Puerto Rico-Qualified Plans to Participate in U.S. Group and Master Trusts for Transition Period, Extends Deadline for Puerto Rico Spin-Offs
The U.S. Internal Revenue Service (IRS) announced tax-qualified retirement plans in Puerto Rico may continue to pool assets with U.S.-qualified plans in group and master trusts described in Revenue Ruling 81-100 until further guidance is issued.
United States
10 Jan 2011
Relief for Failure to File Written Representations with the IRS for Split-Dollar Loans
In several recent private letter rulings, the Internal Revenue Service has granted extensions to taxpayers to file written representations for split-dollar loans. By being covered under a private letter ruling, affected employees were able to avoid significant tax increases of taxable compensation for all prior periods.
United States
15 Dec 2010
2010 Reporting Obligations of Companies with ISO or ESPP Arrangements
Companies with employee exercises of either ISO or ESPP awards during 2010 will be subject to a new IRS tax reporting obligation.
United States
9 Dec 2010
Federal Government´s Acquisition Of Equity Interests Does Not Constitute 409A Payment Event
Treasury EESA Equity Acquisition Transactions do not trigger payments under nonqualified plans.
United States
9 Jun 2009
New 409A Guidance Issued, 457A Guidance Expected Shortly
Employers must ensure that all of their compensatory arrangements are reviewed for 409A compliance and amended as necessary prior to December 31, 2008.
United States
17 Dec 2008
IRS Issues More Section 162(M) Guidance
Public companies subject to the $1 million deduction limit of Internal Revenue Code Section 162(m) should continue to monitor the fallout from IRS Revenue Ruling 2008-13 for further developments, and should give themselves plenty of lead time to implement changes to employment agreements and plan documents.
United States
27 Feb 2008
IRS Ruling Creates Uncertainty Regarding What Constitutes Performance-Based Compensation Under Internal Revenue Code Section 162(M)
The Ruling concludes that amounts otherwise qualifying as performance-based compensation will fail to so qualify where the amounts may be paid upon an executive’s involuntary or "good reason" termination without regard to achievement of performance goals.
United States
14 Feb 2008
IRS Issues Initial Guidance And Limited Transition Relief For Nonqualified Deferred Compensation Plans Subject To New Section 457A
On January 8, 2009, the Internal Revenue Service (IRS) released its initial guidance interpreting new Code Section 457A, which became effective on January 1, 2009.
United States
29 Jan 2008
Key Changes, Surprises and Opportunities in the Final 409A Regulations
On April 10, 2007 the U.S. Treasury Department and the Internal Revenue Service (IRS) issued final regulations under Section 409A of the Internal Revenue Code. The final regulations are effective January 1, 2008, and taxpayers may rely on them for all periods.
United States
20 Apr 2007
Update on IRS Exempt Organization Compensation Review
In public comments made earlier this week, senior Internal Revenue Service (IRS) officials shared a series of significant observations arising from the IRS' current focus on exempt organization executive compensation arrangements.
United States
5 Dec 2005
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