Sunday, July 27, 2008

409A and "Regulatory Cousins" Leading Private Companies to Valuations

"The IRS recently threw down the gauntlet and placed pressure on private companies to get their valuations right at no matter what stage of development they are. The Service has backed up this gesture by exposing private companies to substantial tax liabilities and penalties if they do not."

Manpower Blog Posts 409A Cheat Sheet

409A Cheat Sheet from Manpower Blog

Wednesday, July 2, 2008

IRS May Soon Solve School Teacher 409A Problem

IRS expects that upcoming guidance will solve problem of recurring part-year compensation for school teachers.

"The regulations to be proposed are expected to address certain types of arrangements involving recurring part-year compensation, including common arrangements involving public school employees who provide services during a 10 month school year and elect to be paid ratably over 12 months. It is expected that the regulations would provide that if certain conditions described below are satisfied, §457(f) would not apply to such arrangements. It is also expected that a conforming change will be proposed for regulations under § 409A, so that § 409A also will not apply to such arrangements if such conditions are met."