IRS Issues Final Regulations on Non-U.S. Tax Withholding Under Deferred Compensation Plans, IRAs and Commercial Annuities

The Internal Revenue Service (“IRS”) and the Treasury Department on October 21, 2024, issued final regulations under Sections 3405(a) and 3405(b) of the Internal Revenue Code of 1986, as amended (“Code”). (The IRS had issued previous guidance with respect thereto in Notice 87-7 and the IRS and Treasury had proposed regulations in May 2019.). Code Sections 3405(a) and 3405(b) generally require the payor of any distribution from an employer deferred compensation plan, both tax-qualified and...
By: The Wagner Law Group

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