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Donald Carleen, a partner at Fried, Frank, Harris, Shriver & Jacobson, examines the IRS' recent issuance of proposed regulations that clarify the scope and application of �409A of the Internal Revenue Code. The proposals give guidance on stock valuation and address the modifications of outstanding stock rights and the substitution of stock rights in connection with corporate transactions. Most significant are the rules addressing modifications that would be deemed the granting of a new stock right.
November 03, 2005 at 12:00 AM
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The original version of this story was published on Law.Com
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