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Effect of Severance Arrangements on the Performance-Based Compensation Exception to the $1 Million Deduction Limit
Debra B. Hoffman, Wayne R. Luepker, November 6, 2009
US Internal Revenue Service (IRS) Revenue Ruling 2008-13 (the "Ruling")...describes an incentive compensation arrangement that was generally intended to provide payment only if certain performance goals were attained, but also provided for payment by reason of an executive's involuntary...

Foreign Account Tax Compliance Act of 2009: Information Reporting for US Client Accounts at Non-US Financial Institutions
James R. Barry, Donald C. Morris, Jonathan A. Sambur, November 6, 2009
On October 27, 2009, Senators Baucus and Kerry, together with Representatives Rangel and Neal, introduced the Foreign Account Tax Compliance Act of 2009 (the "Act"). The bill is the product of consultation between Congress and the US Treasury Department (Treasury) and is intended to curb...

Employers Must Act Quickly to Take Advantage of Limited Grace Period for Correcting Certain Operational Violations under Code Section 409A
Rebecca C. Davenport, Maureen J. Gorman, November 4, 2009
Employers must act by the end of 2009 if they want to take advantage of transition relief provided by Notice 2008-113 (the Notice) for certain types of operational violations of the rules under Internal Revenue Code Section 409A that occurred prior to 2008.

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