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other guidance

Applicable Federal Rates

Applicable Federal Rates (AFRs) are used in 280G calculations for determining the present value of payments. The rules provide that the discount rate should be 120% of the AFR for the appropriate term and present valued using semiannual compounding. 

Go to AFRs

IRS Revenue Rulings

IRS Revenue Rulings provide additional guidance in applying the 280G rules. 

Go to Revenue Rulings

IRS Revenue Procedures

IRS Revenue Procedures provide additional guidance in applying the 280G rules.

Go to Revenue Procedures

IRS Notices

IRS Notices provide additional guidance in applying the 280G rules. 

Written Determinations

Written Determinations are IRS guidance subject to public disclosure and include Private Letter Rulings which are rulings issued by the IRS to specific taxpayers seeking guidance.

Go to Written Determinations

Court Cases

Various tax court cases have occurred which addressed 280G golden parachute tax issues.

Full Text of 2003 Final Regulations, including Preamble

The final regulations, when issued, include introductory language which provide readers additional context for the regulations. (Federal Register HTML Version)

Go to Final Regulations

2003 Final Regulations Correction

A correction was made to the 2003 Final Regulations. (PDF Version)

Go to Correction

IRS Audit Techniques Guide, 2017

The IRS publishes a guide to assist its auditors during its audits of 280G (IRS.gov site)

Go to Audit Guide
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