Neil Beaton
This practice aid focuses on the 'nuts and bolts' of performing valuation and allocation analyses specifically related to Internal Revenue Code §409A ('§409A'). The broad scope of this new Code section provides that, unless certain requirements are met, amounts deferred under a nonqualified deferred compensation plan will be currently includible in income and subject to an additional 20% excise tax. Since there are many complexities involved in performing such valuations, and instead of muddying the waters with esoteric discussions about the proper treatment of specific issues, this guide provides a solid foundation for the reader to perform the most common §409A valuations over a wide variety of economic conditions.
