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Deferred compensation

Tax Court -purported welfare benefit plans were nonqualified deferred compensation arrangements

Tax Court -purported welfare benefit plans were nonqualified deferred compensation arrangements

Machacek, Jr., TC Memo 2016-55 In consolidated cases, the Tax Court has concluded that purported welfare benefit plans in which the taxpayers’ companies participated were nonqualified deferred compensation arrangements, and the taxpayers had to include in their gross income any vested accrued benefits in the plan under Code Sec. 402(b)(4), because the plan failed to […]

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Federal Circuit upholds reg imposing FICA tax liability on full value of deferred comp

Federal Circuit upholds reg imposing FICA tax liability on full value of deferred comp

Balestra, Jr. v. U.S., (CA Fed Cir 10/13/2015) 116 AFTR 2d ¶2015-5328 The Court of Appeals for the Federal Circuit has affirmed a lower court decision denying a retiree’s claim for a refund of FICA taxes paid on the full value of deferred compensation that he didn’t and will never receive as a result of […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney