Investment Fund Managers’ Use of Stock Options and Stock Appreciation Rights Under Section 457A in the Wake of Revenue Ruling 2014-18
Author: Jon P. Brose.
Source: Volume 28, Number 02, November/December 2014 , pp.5-13(9)
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Abstract:
Recently issued Revenue Ruling 2014-18 opens the door for fund managers to use Stock Rights to achieve a range of goals varying from accommodating investor demands for multi-year incentive arrangements to achieving tax deferral in fund manager compensation arrangements. The Ruling should offer fund managers more flexibility in structuring tax-efficient compensation arrangements, but they should be wary of the inherent clawback.Keywords: deferred compensation; stock appreciation rights; SARs; Rev. Rul. 2014-18; IRC Sec. 457A; nonqualified stock options
Affiliations:
1: Seward & Kissel LLP.