https://avrenadvisory.com/blog Original analysis on executive security tax compliance: Treas. Reg. §1.132-5, the Independent Security Study, SEC Item 402, and audit defense. en-us Mon, 25 May 2026 16:02:54 GMT https://avrenadvisory.com/blog/cost-of-undocumented-executive-security-program https://avrenadvisory.com/blog/cost-of-undocumented-executive-security-program Mon, 25 May 2026 12:00:00 GMT Cost Analysis A $150,000 executive security program rarely costs a corporation $150,000. Gross-ups, the §162(m) cap, and §280G can more than double it in an ordinary year — and far more in the year the company is sold. Here's the math. https://avrenadvisory.com/blog/employee-nexus-test https://avrenadvisory.com/blog/employee-nexus-test Wed, 15 Apr 2026 12:00:00 GMT ISS Analysis The §1.132-5(m) security exclusion isn't limited to C-suite executives. It's limited by whether the threat arises from the person's role as an employee. Here's how that test works for professional athletes, brand founders, media talent, and roles most people don't consider. https://avrenadvisory.com/blog/above-iss-recommendation https://avrenadvisory.com/blog/above-iss-recommendation Tue, 14 Apr 2026 12:00:00 GMT Compensation Planning The ISS defines the minimum defensible program. Security benefits that go beyond what the study recommends don't inherit the tax treatment of the qualifying program — they're compensation. Here's how that line works and how to plan around it. https://avrenadvisory.com/blog/aircraft-security-exclusion https://avrenadvisory.com/blog/aircraft-security-exclusion Mon, 13 Apr 2026 12:00:00 GMT Tax Treatment Employer-provided aircraft is among the most scrutinized executive compensation items. When an ISS recommends non-commercial aircraft for security reasons, a specific exclusion path opens. Here's what it requires and where companies go wrong. https://avrenadvisory.com/blog/iss-family-members-coverage https://avrenadvisory.com/blog/iss-family-members-coverage Sun, 12 Apr 2026 12:00:00 GMT ISS Programs The IRS working condition fringe exclusion can extend to family members — but only under specific conditions. Here's what the regulation requires, how coverage is structured, and the documentation mistakes that collapse otherwise defensible programs. https://avrenadvisory.com/blog/bona-fide-concern-fact-patterns https://avrenadvisory.com/blog/bona-fide-concern-fact-patterns Sat, 11 Apr 2026 12:00:00 GMT ISS Analysis The most consequential determination in an ISS is whether a bona fide business-oriented security concern exists. Here are six real-world fact patterns that show how that standard applies — including one that doesn't qualify. https://avrenadvisory.com/blog/independence-requirement-iss-providers https://avrenadvisory.com/blog/independence-requirement-iss-providers Fri, 10 Apr 2026 12:00:00 GMT ISS Independence The IRS requires an Independent Security Study to be performed by an independent third party. Most ISS providers fail this requirement structurally - not incidentally. Here's what independence actually means and what to look for when evaluating firms. https://avrenadvisory.com/blog/example-5-consistency-requirement https://avrenadvisory.com/blog/example-5-consistency-requirement Thu, 09 Apr 2026 12:00:00 GMT Audit Defense Treasury Regulation §1.132-5(m) includes its own cautionary tale in Example 5. Here's what it says, why it describes the most common ISS failure pattern, and how to make sure it doesn't apply to your program. https://avrenadvisory.com/blog/what-to-expect-iss-engagement https://avrenadvisory.com/blog/what-to-expect-iss-engagement Wed, 08 Apr 2026 12:00:00 GMT ISS Process How does an ISS engagement actually work? Here's what the process looks like from kickoff to delivery - what you provide, what we produce, how long it takes, and how the final report is handled. https://avrenadvisory.com/blog/irs-vs-sec-executive-security-disclosure https://avrenadvisory.com/blog/irs-vs-sec-executive-security-disclosure Tue, 07 Apr 2026 12:00:00 GMT Tax Compliance A company can exclude executive security costs from the W-2 under IRS §1.132-5 and still be required to disclose them in the proxy under SEC Item 402. Here's how the two regimes work - and why conflating them is one of the most common compliance mistakes. https://avrenadvisory.com/blog/sec-enforcement-executive-perquisite-disclosure https://avrenadvisory.com/blog/sec-enforcement-executive-perquisite-disclosure Mon, 06 Apr 2026 12:00:00 GMT SEC Compliance The SEC has brought repeated enforcement actions against public companies for failing to disclose executive perquisites under Item 402. Here's what went wrong in seven named cases - and what the pattern means. https://avrenadvisory.com/blog/brian-thompson-executive-security https://avrenadvisory.com/blog/brian-thompson-executive-security Sun, 05 Apr 2026 12:00:00 GMT Risk Management The December 2024 killing of UnitedHealthcare's CEO revealed that many large companies have no meaningful security function in place at all. Here's what companies should build - and how to get the regulatory structure right while protecting people now. https://avrenadvisory.com/blog/twenty-four-hour-protection-vs-independent-security-study https://avrenadvisory.com/blog/twenty-four-hour-protection-vs-independent-security-study Sat, 04 Apr 2026 12:00:00 GMT Program Design Treasury Regulation §1.132-5(m) gives companies two pathways to exclude executive security costs from the W-2. Here's how they differ, when each applies, and what the tax consequences look like. https://avrenadvisory.com/blog/four-requirements-defensible-independent-security-study https://avrenadvisory.com/blog/four-requirements-defensible-independent-security-study Fri, 03 Apr 2026 12:00:00 GMT Tax Compliance Treasury Regulation §1.132-5(m)(2)(iv) sets out four specific conditions an Independent Security Study must meet. Here's what each one requires and where most firms fall short. https://avrenadvisory.com/blog/what-is-an-independent-security-study https://avrenadvisory.com/blog/what-is-an-independent-security-study Thu, 02 Apr 2026 12:00:00 GMT Tax Compliance An Independent Security Study lets companies exclude executive security costs from the executive's taxable income. Here's how §1.132-5(m) actually works, who needs one, and what makes a study defensible. https://avrenadvisory.com/blog/is-executive-security-tax-deductible https://avrenadvisory.com/blog/is-executive-security-tax-deductible Wed, 01 Apr 2026 12:00:00 GMT Tax Compliance Executive security costs are taxable compensation by default. Here's how the working condition fringe benefit exclusion under §1.132-5(m) works, what qualifies, and where programs fail on audit.