New Article: Nonqualified Deferred Compensation Rules for Tax-Indifferent Entities (Section 457A) (Posted on December 4, 2023 by )


A new article, Nonqualified Deferred Compensation Rules for Tax-Indifferent Entities (Section 457A), discusses the rules that apply to deferred compensation plans maintained by certain corporations located in tax haven jurisdictions and partnerships owned by such corporations and/or by tax-exempt organizations. Topics covered include:

  • Purpose of Section 457A
  • Application of Section 457A
  • Substantial Risk of Forfeiture
  • Nonqualified Entities
  • Service Providers
  • Nonqualified Deferred Compensation Plans
  • Tax Effect of Section 457A
  • Relationship between Section 457A and FICA Taxes
  • Relationship between Sections 457A and 409A
  • Effective Date and Transitional Rule

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