We have been involved with several transactions where the CIC protections were large enough that the target boards were able to renegotiate part of the employment agreements with their own executives, especially relating to severance or 280G tax
gross up. In one instance, the reductions that the executives accepted were large enough to raise the buyer's offer price.
(10) There is a possibility that the plan could cause a federal tax benefit through the reduction of the section 78
gross up upon payment of a dividend from the CFC.
These practices include golden parachutes, multiyear guaranteed contracts, overgenerous severance arrangements, golden coffins, poison pills, staggered boards, and
gross ups.