FDIC proposes limits on golden parachute payments
Article Abstract:
The US Federal Deposit Insurance Corporation (FDIC) has issued revised proposed regulations limiting the ability of troubled or insolvent financial institutions to make golden parachute payments. Exceptions to the restrictions on such payments include payments pursuant to qualified plans and nondiscriminatory severance plans, payments to an individual that is hired with notice that the FDIC has approved the payments and payments not exceeding 12 months of salary made pursuant to a change of control. The funding requirement for bona fide deferred compensation present in the original proposed regulations has been removed from the revised regulations.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1995
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INDOPCO v. Commissioner: implications for compensation-related payments in corporate transactions
Article Abstract:
Fears of an expanded IRS application of the capitalization doctrine after the INDOPCO decision appear to be unwarranted. The issue is the difference between current expenses and capital expenditures, and the long-held IRS position that payments arising from a corporate transaction but not tendered to meet a prior obligation must be capitalized seems still to be in force. The INDOPCO decision pertained to the classification of compensation-related payments pursuant to a corporate restructuring.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1992
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IRS confirms method for establishing annual periodic payments of distributions from IRA to avoid tax on early distribution
Article Abstract:
The IRS has approved a method for establishing annual payments from an IRA to a person under 59.5 years of age that can avoid the 10% penalty by complying with section 72(t)(2)(A)(iv). The method involved setting an annual distribution amount based on amortization tables, then adjusting for cost-of-living and likely plan earnings.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1995
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- Abstracts: Prop. Regs. explain S corporation passthrough rules. Prop. regs. explain when distribution of controlled stock is tax free
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