This is our first of many alerts during 2017 as the new
administration signals the rollback of many regulations (e.g.,
fiduciary rules and pay ratio). We will keep you posted.
In January 2017, the Internal Revenue Service ("IRS")
released an updated Golden Parachute Payments Audit Technique Guide
("ATG") that covers the examination of golden
parachutes under Internal Revenue Code ("IRC") Sections
280G and 4999.
Background
Golden parachutes are arrangements that provide executives with
significant financial compensation in the event of a change in
ownership or control of the employer corporation. If a golden
parachute is too rich, the executive may incur a 20% excise tax on
"excess parachute payments" and the corporation may lose
the corresponding tax deduction.
