
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 […]