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  • videocam On-Demand
  • signal_cellular_alt Intermediate
  • card_travel ERISA
  • schedule 90 minutes

U.S. Golden Parachute Rules in International Transactions: Sections 280G and 4999, Strategies to Avoid Tax Pitfalls

$347.00

This course is $0 with these passes:

CLE
CPE
ALL
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Description

In the context of cross-border mergers and acquisitions, U.S. golden parachute rules for executive compensation must be considered in the transaction. Advisers and counsel must navigate Internal Revenue Code rules and other compensation regulations and address the key issues.

Golden parachute payments are governed by Sections 280G and 4999 of the Code. If applicable, these Code Sections generally impose a 20 percent excise tax on disqualified individuals for receiving excess parachute payments and deny of corporate deductions for such payments. Critical steps in determining the applicability and impact of the golden parachute rules include determining who are disqualified individuals, considering the nature of the compensation, whether, in fact, a change in control will occur, availability of shareholder approval as a remedy, mitigation planning where shareholder approval is not available, and other vital items.

Practitioners must fully understand these tax issues and other legal implications to avoid pitfalls in structuring and implementing the deal.

Listen as our authoritative panel of tax and executive compensation practitioners guides you through applying the golden parachute rules under IRC Sections 280G and 4999 to cross-border transactions and best practices for counsel to avoid tax pitfalls in structuring a deal.

Presented By

James A. Deets
Senior Director
Alvarez & Marsal Holdings, LLC

Mr. Deets is a Senior Director at Alvarez & Marsal Taxand LLC in Dallas. He specializes in executive compensation, employee benefits and qualified retirement plans and has served as a consulting expert on employee benefits issues within the context of bankruptcy proceedings.

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Ekaterina Napalkova
Partner
Proskauer Rose LLP

Ms. Napalkova advises public and private companies, private investment funds, executives and boards on a broad range of compensation and employee benefits matters. Her practice includes the compensation and employee benefits aspects of mergers and acquisitions, reorganizations, spin-offs, initial public offerings, financings and other corporate transactions. Ms. Napalkova’s practice further focuses on advising clients across various industries on the negotiation, structuring and implementation of benefits and compensation plans and executive compensation arrangements; golden parachutes; securities reporting, registration and disclosure compliance; and corporate governance matters.

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Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).


  • Live Online


    On Demand

Date + Time

  • event

    Wednesday, October 12, 2022

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

  1. Section 280G
  2. Section 4999
  3. Triggering events
  4. Payments and change of control issues
  5. Strategies for minimizing any adverse tax or legal consequences

The panel will review these and other vital questions:

  • When do the golden parachute tax provisions apply in a cross-border transaction?
  • What limits does IRC 280G impose on golden parachutes for executives?
  • How does IRC 4999 apply, and what are the challenges?
  • Who is a disqualified individual under the IRC?
  • What are the implications of payments contingent on a change in control?
  • What are critical strategies for minimizing any adverse tax or legal consequences?

Learning Objectives

After completing this course, you will be able to:

  • Understand the golden parachute rules and limitations under Sections 280G and 4999
  • Identify events that can trigger the golden parachute excise tax
  • Ascertain strategies for minimizing any adverse tax or legal consequence when structuring transactions under Sections 280G and 4999
  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience advising the business or clients on executive compensation matters, at mid-level within the organization, supervising other preparers/accountants. Specific knowledge and understanding of IRS rules and regulations applicable to executive compensation packages, including equity compensation and nonqualified deferred compensation. Familiarity with ERISA, Treasury Regulations and IRS guidance relevant to tax implications for executive compensation structures.

BARBRI is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .