Often, executives of private companies have certain rights and benefits that are triggered upon a change in control, such as accelerated vesting of equity awards and payments under a management carve-out plan.  These payments may result in significant tax penalties under Section 280G of the Internal Revenue Code, or the “Golden Parachute Rules”, unless appropriate action is taken by the company.  Section 280G was enacted by Congress in an attempt to discourage the payment of significant compensation to executives of companies as “golden parachutes” in connection with an exit event, at the expense of other stockholders. Continue reading....