Jan 31, 2006 – Proposed Code Section 409A Regulations Prompt Reconsideration of Stock Valuations for Equity Compensation Programs. Compensation .

Land value tax . There are various exceptions, excluding from the Section 409A rules compensation that would otherwise fall within this definition, including: .

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Such methods include, for example, the valuation method described in Section 20.2031-2 of the Estate Tax Regulations. Question: When is Section 409A .

Apr 19, 2007 – Section 409A was added to the Code by the American Jobs . The final regulations reflect the three valuation safe harbors set forth in the .

Apr 13, 2007 – On April 10, 2007 the U.S. Treasury Department and the Internal Revenue Service (IRS) issued final regulations under Section 409A of the .

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Apr 19, 2007 – Proposed regulations under Section 409A were released in October . of the fair market value of a share of stock on the date of exercise over .

Section 409A Valuation. The IRS has changed the rules governing deferred compensation. Newly promulgated Internal Revenue Code Section (IRC) 409A sets .

Plan sponsors should remain mindful of the section 409A rules when making grants, . Fair market value (FMV) stock options and SARs issued in the employer's .

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Valuation of stock at the date of grant thus becomes critical in determining whether Section 409A applies to an option grant. The regulations provide extensive .

§409A Option Valuation Regulations Issued. May, 2007 | Issue 18. Introduction On April 10, 2007, the Treasury Department and the IRS issued final regulations .

Proposed Section 409A Regulations . The proposed regulations state that the value of public company stock may be determined based on market reported .

May 3, 2007 – Impact of Section 409A on nonqualified deferred compensation . . The final regulations provide that the fair market value of the stock may be .

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Almost two and a half years after Congress enacted Section 409A of the . The final regulations establish certain rules for establishing fair market value.2 .

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Apr 11, 2007 – IRS Releases Final Section 409A Regulations on Deferred . . the Regulations include a presumption that a specified valuation of stock reflects .

409A valuation opinions from an expert third-party on the fair market value of . value indicators to help private companies efficiently comply with regulations and .

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Observation: The regulations under section 409A contain extensive rules regarding the valuation of closely held and start-up companies with no public market .

Business Valuation Services . The §409A regulations offer the following solutions for private companies that want to avoid the adverse tax consequences that .

Dec 8, 2008 – Library. Compensation Arrangements: Code Section 409A - Special Rules for . What constitutes “fair market value” for purposes of the 409A .

Jan 10, 2006 – Stock Rights will be deemed to satisfy the fair market value rules established under Section 409A as long as the "good faith" incentive stock .

Generally 409A mandates that all arrangements enforce rules concerning the employees' ability to defer income and receive the value of deferred income. .

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409A is no longer a proposed regulation and has officially taken effect January 1, 2009. . The regulations state that for the IRS to accept a valuation of private .

Jan 19, 2008 – Highlights of the Final Section 409A Regulations (published April 16, 2007). Stock Rights . Well, the 409A valuation issue is not going away. .

Section 409A generally provides that all amounts deferred under a nonqualified . . regulations' consistency standard with respect to the valuation of stock rights. .

On April 10, 2007, the IRS issued the long-awaited final regulations under Section 409A of the IRC, which are expected to significantly and immediately affect .

Jan 1, 2006 – To the extent these rules are not met, Section 409A taxes . In addition, the proposed regulations designate three valuation methods that will be .

Next, it describes the valuation rules that are established by the Section 409A guidance issued by the IRS, including the Safe Harbors. It then describes the .

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Proposed regulations. Proposed regulations issued under Section 409A on September 29, 2005, set forth reasonable valuation method presumptions for .

Dec 18, 2005 – The 409A valuation rules do not affect a carveout plan, but there are other (more complicated) 409A rules that do affect the structure. .

In order to abide by §409A and avoid early income recognition and additional taxes by the option holder, §409A's valuation rules must be followed. In 2010, the .

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May 7, 2007 – Section 409A also includes rules applicable to certain trusts or . . adopt the rules under the proposed regulations governing valuation of stock .

"The final regulations adopt a presumption in specified circumstances that, for purposes of section 409A, a valuation of stock reflects the fair market value of the .

As described in our previous alert, the determination of fair market value under the proposed Section 409A Regulations requires a much more rigorous .

However, stock options and SARs tied to preferred stock are subject to 409A. Detailed rules and restrictions apply, including: valuation rules; rules governing .

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The risk to the company comes in the event options have been issued with a strike price below the company's true value, in which case IRS Reg 409A kicks in .

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