base amount

(A)The term “base amount” means the individual’s annualized includible compensation for the base period. (B)The portion of the base amount allocated to any parachute payment shall be an amount which bears the same ratio to the base amount as— (i)the present value of such payment, bears to (ii)the aggregate present value of all such payments.

Source

26 USC § 280G(b)(3)(A)


Scoping language

For purposes of this section
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