The IRS recently released guidance regarding the 2017 Tax Act amendments to Section 162(m) of the Internal Revenue Code, which generally apply to taxable years beginning or after Jan. 1, 2018. IRS Notice 2018-68 provides...more
Last week, the Internal Revenue Service (IRS) proposed new regulations under Section 457 of the Internal Revenue Code (Code), which governs nonqualified deferred compensation plans of state and local governments and private...more
In a Chief Counsel Memorandum issued last month, the IRS concluded that an executive retention arrangement violated Section 409A despite the employer’s efforts to correct the arrangement before the retention bonus vested....more
The final Section 162(m) regulations issued by the IRS last week have a small but welcome surprise for companies that have recently become public....more
The Internal Revenue Service (IRS) recently issued final regulations under Section 162(m) of the Internal Revenue Code (Code). The final regulations are substantially similar to the proposed regulations issued by the IRS in...more
Over the last decade, the IRS has assumed a broader role in the governance of tax-exempt organizations and embraced the view that transparency leads to tax compliance. Nowhere is the IRS s approach more evident than in the...more