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IRS Issues Proposed Regulations Under Code Section 162(m)

The 2017 Tax Cuts and Jobs Act (TCJA) significantly amended Internal Revenue Code Section 162(m), which generally disallows the deduction of compensation in excess of $1 million paid by a “publicly held corporation” to a...more

The Section 4960 Excise Tax: Application to Tax-Exempt and Affiliated Taxable Entities

Federal tax law changes enacted with the Tax Cuts and Jobs Act of 2017 may require tax-exempt organizations to reevaluate their compensation practices, particularly with respect to employee severance. Section 4960 of the...more

Tax Act: New Opportunity to Defer Income from Certain Private Company Equity Grants

The new Section 83(i) of the tax code, enacted as part of the Tax Act, allows certain private company employees to elect to defer, solely for income tax purposes and for a period of up to five years, the income attributable...more

Tax Act: Taxation of Fringe Benefits After Tax Reform

The Tax Act makes changes to the tax treatment of fringe benefits that impact both employers and employees. Employers are now denied certain deductions to which they were previously entitled, including expenses for parking...more

Tax Act: Deductibility of Executive Compensation After Tax Reform

Section 162(m) of the Code generally disallows the deduction of compensation in excess of $1 million paid by a public company to a “covered employee” in any single taxable year. The Tax Act makes the following changes to...more

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