TaxProf Blog

Editor: Paul L. Caron, Dean
Pepperdine University School of Law

Friday, March 30, 2007

Halperin & Yale on Deferred Compensation Revisited

Ssrn_4Daniel I. Halperin (Harvard) & Ethan Yale (Georgetown) have posted Deferred Compensation Revisited on SSRN.  Here is the abstract:

The tax rules governing deferred compensation, codified at section 409A, are harsh and complex. The rules are focused on the least important policy considerations and overlook the most important. Professors Halperin and Yale suggest a different approach, one that would make the law simpler, fairer, and more effective.

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An executive with deferred comp terminates and changes resident state. When deferred comp is then distributed, which state (current "lived-in" or former "worked-in" taxes should be with held as liability?

Posted by: Ray Slogar | Apr 6, 2007 7:19:55 AM