Taxation of Executive Compensation (Full-Day Course) (Completed)

A large portion of the rise in executive pay over the last two decades has come in the form of deferred compensation. Stock options, annuities, and life insurance policies, in addition to more traditional nonqualified deferred compensation plans, are all common means of compensating highly paid executives.

This course addresses the numerous tax rules that reach deferred compensation arrangements and often discourage their use, including I.R.C. sections 162(m), 409A, and 280G, It also addresses the taxation of common incentive based compensation arrangements such as stock appreciation rights and payments triggered upon changes in control. Finally, it will briefly address SEC rules such as the "say for pay", "pay ratio", and "performance based compensation rules."

Who Should Attend
Tax practitioners at all levels who advise on the taxation of executive compensation.

Topics Covered

• Taxation of employee stock options
• Tax consequences of compensation based life insurance policies
• Section 409A's penalty provisions affecting deferred compensation
• Section 162(m)'s denial of deduction for "excessive compensation"
• Deduction disallowance for payments triggered upon changes in control
• SEC rules applying to executive compensation

Learning Objectives

• Explain the tax treatment of various types of employee stock options
• Identify situations where IRC rules may limit or disallow deduction of executive compensation payments
• Describe situations in which penalty taxes may apply to payments received by executives
• Familiarity with pay ratio and pay for performance rules.

Level
Intermediate

Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (8 hours)

Program Prerequisites
A basic understanding of taxation of executive compensation.

Advance Preparation
None