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Stranger in a Strange Land: Surprising Applications of U.S. Golden Parachute Rules in Cross-Border Transactions

Proskauer's Employee Benefits & Executive Compensa

The “golden parachute” excise tax regime under Internal Revenue Code Sections 280G and 4999 (“Section 280G” and “Section 4999”, respectively) is at the core of both public and private U.S.-based compensation tax deduction. When Do the Golden Parachute Tax Provisions Apply? Background. based transactions. corporations.