Open Access. Powered by Scholars. Published by Universities.®
- Keyword
-
- Executive compensation (2)
- Age Discrimination in Employment Act (1)
- Agriculture (1)
- Almon study (1)
- Americans with Disabilities Act (1)
-
- Automotive products (1)
- Border pollution (1)
- Capital (1)
- Competition policy (1)
- Constructive receipt (1)
- Corporate governance (1)
- Customs (1)
- Deferral (1)
- Deferred compensation (1)
- Dispute settlement (1)
- Domestic marketplace (1)
- Duties (1)
- Economic benefit doctrine (1)
- Egypt (1)
- Egyptian government (1)
- Employment discrimination (1)
- Energy (1)
- Environmental enforcement (1)
- Environmental protection (1)
- Executive Compensation Strategy (1)
- Exemption (1)
- Export (1)
- Expropriation (1)
- Federal income tax (1)
- Financial services (1)
- Publication Type
Articles 1 - 9 of 9
Full-Text Articles in Tax Law
A Practitioner's Guide To United States Employment Taxation Of Nonresident Aliens Working In The United States, John L. Gornall Jr., John B. Copenhaver
A Practitioner's Guide To United States Employment Taxation Of Nonresident Aliens Working In The United States, John L. Gornall Jr., John B. Copenhaver
Georgia Journal of International & Comparative Law
No abstract provided.
The Development Of Foreign Investment Law In Egypt And Its Effect On Private Foreign Investment, George E. Bushnell Iii
The Development Of Foreign Investment Law In Egypt And Its Effect On Private Foreign Investment, George E. Bushnell Iii
Georgia Journal of International & Comparative Law
No abstract provided.
The North American Free Trade Agreement (Nafta): Good For Jobs, For The Environment, And For America, Thomas J. Schoenbaum
The North American Free Trade Agreement (Nafta): Good For Jobs, For The Environment, And For America, Thomas J. Schoenbaum
Georgia Journal of International & Comparative Law
No abstract provided.
Fixing Section 409a: Legislative And Administrative Options, Gregg D. Polsky
Fixing Section 409a: Legislative And Administrative Options, Gregg D. Polsky
Scholarly Works
This symposium contribution to the Villanova Law Review describes the legislative calamity that is section 409A of the Internal Revenue Code. Section 409A manages, all at once, to (i) fail to better neutralize the tax treatment of deferred compensation with that of current compensation, (ii) impose significant compliance costs on sophisticated taxpayers, and (iii) provide a dangerous trap for unsophisticated taxpayers.
Ideally, Congress should repeal section 409A and replace it with a system that taxes deferred compensation more neutrally vis-a-vis current compensation. Failing that, Congress should either replace section 409A with a broad grant of authority to the Treasury and …
Controlling Executive Compensation Through The Tax Code, Gregg D. Polsky
Controlling Executive Compensation Through The Tax Code, Gregg D. Polsky
Scholarly Works
This article analyzes Internal Revenue Code § 162(m), which in general denies public companies a deduction for annual non-performance-based compensation in excess of $1,000,000 paid to senior executive officers. Congress enacted § 162(m) with the intent to reduce the overall level of executive compensation and to influence the composition of executive compensation in favor of components that are more sensitive to firm performance. Notably, § 162(m) represents the most direct Congressional effort to influence executive compensation design. In light of recent events, Congress is being called upon to once again address the perceived problem of overgenerous executive pay packages. Accordingly, …
Reforming The Taxation Of Deferred Compensation, Gregg D. Polsky, Ethan Yale
Reforming The Taxation Of Deferred Compensation, Gregg D. Polsky, Ethan Yale
Scholarly Works
Executive pay is currently a topic of significant interest for policymakers, academics, and the popular press. Just weeks ago, in reaction to widespread press reports and academic criticism of extravagant executive perquisites, the SEC proposed new regulations designed to change fundamentally the manner in which executive compensation is reported to share-holders. Despite all of this attention, one significant aspect of executive deferred compensation has gone virtually unnoticed - the federal tax rules governing this form of compensation are fundamentally flawed and must be extensively over-hauled. These rules are flawed because they often create a significant incentive for companies and their …
Taxing The Promise To Pay, Gregg D. Polsky, Brant J. Hellwig
Taxing The Promise To Pay, Gregg D. Polsky, Brant J. Hellwig
Scholarly Works
The IRS recently disclosed that it has identified more than 100 executives at 42 leading public corporations that participated in a tax shelter designed to defer the recognition of income from the exercise of stock options. While the agency thus far has identified approximately $700 million in unreported gains from these shelters, it predicts that the revenue loss to the government will ultimately exceed $1 billion. Compared to most tax shelters, this particular transaction (commonly known as the "Executive Compensation Strategy" or "ECS") is remarkably simple. Rather than exercise the options individually, a participating executive instead transfers the options to …
Employment Discrimination Remedies And Tax Gross Ups, Gregg D. Polsky, Stephen F. Befort
Employment Discrimination Remedies And Tax Gross Ups, Gregg D. Polsky, Stephen F. Befort
Scholarly Works
This article considers whether a successful employment discrimination plaintiff may be entitled, under current law, to receive an augmented award (a gross up) to neutralize certain adverse federal income tax consequences. The question of whether such a gross up is allowed, the resolution of which can have drastic effects on litigants, has received almost no attention from practitioners, judges, and academics. Because of the potentially enormous impact of the alternative minimum tax (AMT) on discrimination lawsuit recoveries, however, the gross up issue is now beginning to appear in reported cases.
The three principal federal anti-discrimination statutes - Title VII, the …
State Taxation Of Nonresidents' Pension Income, Walter Hellerstein
State Taxation Of Nonresidents' Pension Income, Walter Hellerstein
Scholarly Works
This article examines the issues raised by the efforts of some states to tax the pension income of their former residents and of the proposed congressional legislation to forbid such taxation. While there may be sound policy reasons for forbidding state taxation of nonresident pension income, they have yet to emerge clearly from the rhetoric that has thus far dominated the debate over the pension tax issue. The goal of the article is to examine the questions raised by the controversy over state taxation of nonresident pensions in the hope that dispassionate analysis of the problem may contribute to a …