§4985. Stock compensation of insiders in expatriated corporations — Inbound Citations
26 U.S.C. § 4985
Cited by 2 provisions in release 119-102.
Citations to 26 U.S.C. § 4985 as a whole
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(E) The dollar limitation contained in paragraph (1) with respect to any covered employee shall be reduced (but not below zero) by the amount of any payment (with respect to such employee) of the tax imposed by section 4985 directly or indirectly by the expatriated corporation (as defined in such section) or by any member of the expanded affiliated group (as defined in such section) which includes such corporation.
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(A) Any amount deferred under a nonqualified deferred compensation plan shall be taken into account for purposes of this chapter as of the later of—(i) when the services are performed, or(ii) when there is no substantial risk of forfeiture of the rights to such amount.The preceding sentence shall not apply to any excess parachute payment (as defined in section 280G(b)) or to any specified stock compensation (as defined in section 4985) on which tax is imposed by section 4985.