PRACTICE AREASection 280G: Golden Parachute Counsel
The most consequential issue in your deal - handled with speed and precision.
WHAT IS SECTION 280G?Section 280G of the Internal Revenue Code governs "golden parachute" payments — compensation triggered by a change in control that can carry a 20% excise tax on the executive and a full tax deduction disallowance for the payor. In corporate transactions, getting the analysis right — and getting it done quickly — can be the difference between a smooth close and a costly delay.
HOW WE WORK01
Triage & Screening
We begin with a rapid assessment of potential parachute payment exposure — identifying affected individuals, flagging material risks, and providing deal teams with a clear picture of where attention is needed.
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Full Section 280G Analysis
When a comprehensive analysis is required, we manage the full process: base amount calculations, present value determinations, identification of all potential parachute payments, and application of relevant safe harbors and exceptions.
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Migration & Structuring
We advise on strategies to reduce or eliminate excess parachute payment exposure — including cutback provisions, modified compensation structures, and shareholder approval procedures under the §280G regulations.
WHY NUÑEZ LAWDeep §280G experience gained at White & Case LLP across M&A, PE-backed, and restructuring transactions.
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Deal-oriented approach: timely, practical analysis designed to fit transaction timelines without sacrificing precision.
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Technology-enhanced process: our developing ParachuteIQ platform brings additional speed and precision to every analysis.
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Close coordination with corporate, tax, and accounting teams to integrate seamlessly into deal execution.
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Need a Section 280G Analysis?
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