Paul Hastings was the first that we knew of to actually compile and publish a redline of the final 409A regulations. One pertinent section begins on page 38 with the words "presumption of reasonableness." Here’s where you get the valuation safe harbors.
To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in Arcstone communications, unless expressly stated otherwise, is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any tax-related matter(s) addressed herein.
This is our way of saying that Arcstone does not give tax advice. We provide valuations, not tax advice.
Paul Hastings was the first that we knew of to actually compile and publish a redline of the final 409A regulations. One pertinent section begins on page 38 with the words "presumption of reasonableness." Here’s where you get the valuation safe harbors.