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nonqualified deferred comp (NQDC) plans

IRS draws conclusions regarding taxpayer’s income from nonqualified stock option

IRS draws conclusions regarding taxpayer’s income from nonqualified stock option

Chief Counsel Advice 201603025 In Chief Counsel Advice (CCA), IRS drew various conclusions regarding a taxpayer recognizing income form a nonqualified stock option that he received, including whether the underlying stock was readily tradable on an established securities market. Background. Under Code Sec. 409A(a)(1)(A), all amounts deferred under a nonqualified deferred compensation (NQDC) plan for all […]

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Audit Guide Provides Roadmap For Reviewing Nonqualified Deferred Comp Plans

Audit Guide Provides Roadmap For Reviewing Nonqualified Deferred Comp Plans

IRS has updated its Audit Techniques Guide (ATG) focusing on nonqualified deferred comp (NQDC) plans. It provides auditors with a roadmap to some of the issues in this area, and what to look for when reviewing such plans. Although intended to provide instruction to IRS examiners, the ATG provides insight to the issues that might […]

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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