, which will be at the closing of the deal in December, 2019, just like it says in reg. 1.1001-2(a).as the amount of the liability is properly included in the amount realized on the transaction by the taxpayer.
OK, not sure why
The type of taxable income does.
.Pursuant to § 1.404(a)-12(b)(2) of the Income Tax Regulations, and provided that they otherwise meet the requirements for deductibility, contributions or compensation deferred under a nonqualified plan or arrangement are deductible in the taxable year in which they are paid or made available, whichever is earlier.
and this way:The Plan also provides that in the event of a sale or other change of control of X representing 80 percent or more of the Company’s outstanding voting shares, participants have the right to surrender all SAR’s immediately prior to the sale, at which time the SAR’s would otherwise terminate.
.Thus, as of June 15, 1999, all outstanding SAR’s had been awarded more than a year earlier and were therefore immediately exercisable. By resolution of the X Board of Directors, all SAR’s were deemed and treated as surrendered and all participants were paid for their SAR’s on the day immediately preceding the change of control: June 29, 1999. Participants will include the SAR payments in income for the taxable year ending December, 1999.
... a contribution paid or incurred with respect to a nonqualified plan, method or arrangement, providing for deferred benefits is deductible in the taxable year of the employer in which or with which ends the taxable year of the employee in which the amount attributable to the contribution is includible in the gross income of the employee.
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