Description
Understand the general categories of executives to which section 280G applies and the methods available to reduce or eliminate exposure.Under the Internal Revenue Code (IRC), corporations that make excess parachute payments lose significant tax deductions, and the recipient is subject to a 20 percent excise tax on such excess payments. Additionally, excess parachute payments can further limit the deductibility of other compensation paid by the corporation. This presentation will help the audience gain knowledge of the rules and assess the tax impact on corporations and employees when golden parachutes are triggered by a change in control of the employer. The live webinar also explains various issues that corporations should keep in mind when applying mitigation techniques prior to or after the change in control.
Date: 2024-02-29 Start Time: End Time:
Learning Objectives
What Is Section 280G
• Overview
• Payments/Benefits Covered by the Golden Parachute Rules
• Tax Implications
Golden Parachute Rules • Section 280G
• Base Amount
• 3X Base Amount (Safe Harbor)
• Parachute Payments
• Excess Parachute Payments
Section 280G Exemptions
• Small Business Corporation
• Tax Exempt Entity
• Non-Public Corporation With Shareholder Approval
Section 280G Mitigation Concepts
• Base Amount Planning
• Reasonable Compensation Prior to the Cic
• Reasonable Compensation After the Cic
Other M&A Compensation Issues
• Earnouts
• Adjusting Stock Options Upon a Transaction
• Impact on Tax Deduction
AIPB ,CLE (Please check the Detailed Credit Information page for states that have already been approved) ,HR Certification Institute ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.
Riley Dinh-Alvarez & Marsal, Matthew Porter – Alvarez & Marsal
