Updated
Updated · Foley & Lardner LLP · Jul 30
Foley Flags 10 Executive Contract Risks in Webinar on Pay, Tax and Severance
Updated
Updated · Foley & Lardner LLP · Jul 30

Foley Flags 10 Executive Contract Risks in Webinar on Pay, Tax and Severance

2 articles · Updated · Foley & Lardner LLP · Jul 30

Summary

  • Foley’s webinar said executive employment agreements should be drafted across the full employment lifecycle, with 10 recurring risk areas that can reshape compensation, severance, tax treatment and later disputes.
  • Section 409A, Sections 280G and 4999, and plan-governance rules were highlighted as key pressure points because bonus timing, equity terms, severance structure and change-in-control payouts can trigger unintended tax and compliance consequences.
  • Salary definitions, work location, benefits eligibility and disability language were cited as foundational terms, since small drafting choices can affect bonus formulas, good-reason rights, governing law and benefit obligations.
  • Restrictive covenants and whistleblower carveouts also need regular updates as state law and enforcement priorities evolve, while companies were urged to align employment agreements with equity, bonus and benefit plans to preserve flexibility and cut dispute risk.

Insights

Could a simple remote work clause in an executive contract trigger a hidden 20% tax penalty and derail a merger?
Are your company's legacy executive contracts secretly acting as ticking tax bombs during a change in control?
Why are seemingly routine severance agreements suddenly exposing companies to massive ERISA violations and IRS excise taxes?