TaxLawyer1978 Posted January 5, 2018 Report Share Posted January 5, 2018 A client wants to terminate a phantom stock plan. No shares have vested and value of shares minimal. There would be no distributions on termination, therefore no acceleration on distributions. Are we subject to the rules on terminations under 409A? in other words, can we only terminate if one of the 3 tests in 409A is met? Does it matter if there is no acceleration on distributions here because no distributions would be made. Follow up on this. So the client is now thinking converting to an LLC and offering those same execs some type of an option plan. I imagine that's improper substitution, but thoughts? Thanks Link to comment Share on other sites More sharing options...
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