Extract to table

In particular, compliance with Section 409A of the Code (governing nonqualified deferred compensation) must be confirmed for all outstanding stock options, and the treatment of RSU cashouts under Section 83 must be properly structured

The IRS has consistently interpreted this requirement to mean that at least 80% of the total merger consideration must consist of voting stock of the parent corporation

While a limited amount of non-stock consideration ("boot") is permitted, the transaction must still satisfy an 80% stock test

BRB, as the acquiring corporation, or the paying agent engaged to facilitate the payment of merger consideration, must comply with applicable federal tax withholding and reporting obligations

Under Section 3406 of the Code, the payor is required to withhold federal income tax at the rate of 24% on reportable payments (including merger consideration payments) made to U

Under Section 6045 of the Code, the payor is required to file information returns (IRS Form 1099-B) reporting the gross proceeds paid to each Tessera stockholder in connection with the merger