409A Structured Attorney Fees IRS Issues Guidance
December 20th, 2004WASHINGTON, DC, December 20, 2004 – The IRS and Treasury issued regulatory guidance for Section 409A exccluding structured attorneys fees from Section 409A, making it favorable to structuring attorney fees.
Under this Treasury/IRS guidance, the new section 409A, deferred compensation rules will not apply to arrangements between an attorney and his or her client, where the attorney is actively engaged in the practice of law and provides legal services during the year to two or more clients who are unrelated to the attorney as well as to each other.
Section 409A was enacted as part of the American Jobs Creation Act of 2004 and is generally effective the first of 2005. Many questions have arisen since the enactment of Section 409A as to the impact it would have on structuring attorney fees.
The guidance, which is published as IRS Notice 2005-1, is in the form of 38 questions and answers that address certain aspects of the scope and mechanics of Section 409A. [IRS Notice 2005-1, Q&A-8 (copy attached for reference), to be officially published in 2005-02 Internal Revenue Bulletin (January 10, 2005).]
This is the year of the Presidential election. How many of you are diligently watching all the stuff going on with the political figures ... 
Could the economy get even worse? 2011 will be remembered as the year of disaster capitalism. Almost $6.3 trillion was wiped from the global markets. ... 
