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.
IRS Revenue Rulings provide additional guidance in applying the 280G rules.
IRS Revenue Procedures provide additional guidance in applying the 280G rules.
IRS Notices provide additional guidance in applying the 280G rules.
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.
Various tax court cases have occurred which addressed 280G golden parachute tax issues.
The final regulations, when issued, include introductory language which provide readers additional context for the regulations. (Federal Register HTML Version)
A correction was made to the 2003 Final Regulations. (PDF Version)
The IRS publishes a guide to assist its auditors during its audits of 280G (IRS.gov site)
Copyright © 2020 280G.com - All Rights Reserved.