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Martin A. Goldberg, Robert E. Wnek, Gregory J. Russo, Cynthia Kruth
Internal Revenue Code (the Code) 409A creates special rules for nonqualified deferred compensation plans, including discounted stock options, severance arrangement, and even some expense reimbursement arrangements. The primary themes of Section 409A are ...
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Martin A. Goldberg, Robert E. Wnek, Presley Rodricks, Cynthia Kruth
Carried interest is a form of deferred compensation payable to managers of hedge funds organized as investment partnerships. There are two tax components of this compensation that are favorable to the manager. First, income taxes are due only when amount...
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