Technical Advice Memorandum (TAM) 200040004 discussed the idea that guaranteed premiums are paid to an employee as a mechanism to help the worker pay the loan (unlike the loan is granted) could prevent his treatment as a good faith debt, so that all income collected is considered compensation in the year of receipt. In the case reviewed in the TAM, the employee never had control and control over the premiums, as the amounts were directly used to repay the balance of the credit. Thus, the employee never had access to the fortune because the credit repayment denied the bonus. As premiums were not excluded from gross income, the initial receipt of the loan proceeds was considered the only taxable event and the proceeds were taxable during the year. Under: loans forgivable to employees, non-compete guarantees, restrictive agreements Tagged With: deferred compensation, workers` issuance, employment contract, employment contract and employment contract, execrable credits, icy credits and end-of-life restrictions, non-compete agreements, restrictive agreements, termination of employment An increasingly popular vehicle in the search for potential collaborators is the offer of a forgivable loan issued at the beginning of employment. The concept provides that the worker receives a cash down payment, similar to a sign-up bonus, when the corresponding income from the remittance of such debt is recorded over the duration of the contract commitment. Clearly outlined in the agreement should be the conditions that would trigger the pardon of the loan. An example could be that 20% of the loan will be granted on each of the first five one-year anniversaries after the start of the agreement. Delay provisions should also be included in the agreement. These provisions could summarize the measures taken by the employer to repair the outstanding credit when the employee is no longer employed – for example, the outstanding credit is due within 10 days of the end of the period.