Summary
Devon Energy Corp./DE (DVN) filed an 8-K on April 25, 2011, to disclose material changes to its executive employment agreements. Specifically, the Company amended these agreements with its executive officers, effective April 19, 2011, to eliminate tax gross-up obligations related to change-in-control severance payments. This amendment aims to mitigate potential excise taxes imposed on excess parachute payments under Section 4999 of the Internal Revenue Code. Under the amended terms, instead of the Company covering any excise taxes through gross-up payments, executive officers will either have their severance benefits reduced to avoid the tax, or receive the full severance without any additional tax coverage, whichever is more beneficial on an after-tax basis for the executive. This change is significant for investors as it reflects a move to better manage executive compensation costs and potential liabilities associated with change-in-control events.
Key Highlights
- 1Amendment to executive employment agreements eliminates Company tax gross-up obligations for change-in-control severance.
- 2Objective is to avoid excise taxes imposed on excess parachute payments (Section 4999 of the IRC).
- 3Executives will either have severance reduced to avoid taxes or receive full severance without gross-up, based on better after-tax outcome.
- 4Effective date of the amendment is April 19, 2011.
- 5Filing is an 8-K Current Report filed on April 25, 2011.
- 6The Form of Amendment No. 1 is incorporated by reference from a prior 10-K filing.