An Appreciation for Fund-Based Deferred Compensation
Bloomberg BNA Pension & Benefits Daily, 2014
6 Pages Posted: 22 Jun 2014 Last revised: 7 Aug 2014
Date Written: June 20, 2014
Section 457A of the Internal Revenue Code restricts the ability of certain off-shore and other entities to defer compensation of their service providers on a tax-effective basis. IRS Revenue Ruling 2014-18 confirms that certain stock options and stock appreciation rights are not "deferred compensation" to which Section 457A applies. The article discusses the ruling, and its possible impact.
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