Kerry, Emanuel Propose Offshore Deferred Compensation Reform Act of 2007
Senator Kerry and Representative Emanuel have introduced legislation titled the "Offshore Deferred Compensation Reform Act of 2007." They have provided a summary of the proposed legislation (accessible through http://taxprof.typepad.com/), and you can also view Senator Kerry's press release.
The legislation would create a new Section 457A of the Internal Revenue Code that would eliminate the ability of U.S. taxpayers to defer nonqualified deferred compensation in offshore tax havens. Offshore nonqualified deferred compensation paid by foreign corporations would be taxable income when there was no substantial risk of forfeiture.
The legislation itself was not yet available when we posted this entry. When it is available, you will be able to find it at this link.