Partnership entitled to deduction for compensatory stock options and SARs granted to partnership employees by corporation/general partner
Article Abstract:
The IRS in private letter ruling 9822012 allowed deductions under IRC section 404(a) for nonqualified stock options and stock appreciation rights given by a general partner Subchapter C corporation to employees of the deducting partnership. The unusual fact situation resulted in a section 404(a) rather than a section 162 deduction. Planning for similar tax treatment of deferred compensation plans may be possible in related business groups.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1998
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Charitable contribution deductions for split-dollar insurance transactions disallowed
Article Abstract:
This article concerns the IRS ruling in Notice 99-36 that charitable deductions under IRC sections 170 and 2522 will not be available for contributions made utilizing split-dollar insurance arrangements. The IRS included the warning that penalties may attach to the use of such arrangements, including loss of tax-exempt status.
Publication Name: Tax Management Compensation Planning Journal
Subject: Law
ISSN: 0747-8607
Year: 1999
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