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IRS Proposes Regulations on Expanded Definition of Covered Employee Under Code Section 162m

Section 162(m) of the Internal Revenue Code prohibits a publicly held corporation from taking compensation-related tax deductions with respect to the compensation of a “covered employee” to the extent the compensation exceeds...more

Executive Compensation Considerations if IPO Markets Pick Back Up in 2025

After a recent slower period of activity in the initial public offering (IPO) markets, there has been speculation in accounting and finance markets that there might be an increase in activity over the course of the 2025...more

Executive Compensation and Employee Benefits Fallout After Sweeping FTC Ban on Noncompetes: Part 4—Timing of Taxation under Code...

This is the fourth part of a multi-part blog post series discussing the implications and fallout from the Final Rule recently adopted by the Federal Trade Commission (FTC) banning the enforcement of almost all noncompete...more

Corporate Transactions: Considerations for Addressing Equity Awards

In corporate transactions of all kinds—mergers, acquisitions, and other business combinations—the purchaser company (Purchaser) must confront the question of how to treat the outstanding equity awards and the current equity...more

Executive Compensation and Employee Benefits Fallout After Sweeping FTC Ban on Noncompetes: Part 2—Prohibited vs. Permissible...

This is the second in a multipart series on ML BeneBits discussing the implications and fallout from the Final Rule recently adopted by the Federal Trade Commission (FTC) banning the enforcement of almost all noncompete...more

Executive Compensation Fallout After Sweeping FTC Ban on Noncompetes: Part 1—The Who, What, When, and What to Do Now

On April 23, the Federal Trade Commission (FTC) approved by a 3-2 vote a Final Rule that, if it becomes effective, will ban almost all noncompete clauses for nearly all workers. This is the first in a blog series exploring...more

SEC Approves December 1 as Required Compliance Date for Listing Exchange Clawback Requirements

The Securities and Exchange Commission (SEC) approved on June 9 amended versions of the listing exchange standards by the New York Stock Exchange and Nasdaq. Consequently, the clawback rules will become effective on Monday,...more

NYSE, Nasdaq Set December 1, 2023 Compliance Date for Dodd-Frank Clawback Listing Standards

The New York Stock Exchange (NYSE) and Nasdaq, on June 5 and June 6, respectively, amended the proposed listing standards they previously submitted to the US Securities and Exchange Commission (SEC) to extend the compliance...more

SEC Indicates Early August 2023 May Be Deadline for Adoption of Dodd-Frank–Compliant Clawback Policies

In accordance with the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), new rules directing national securities exchanges, including the New York Stock Exchange (NYSE) and Nasdaq Stock Market (Nasdaq),...more

Preparing for SEC’s Clawback Policies: 10 Compliance Tips for Public Companies

Last fall, the US Securities and Exchange Commission (SEC) announced that it had adopted new rules directing national securities exchanges, including the New York Stock Exchange (NYSE) and Nasdaq, to establish listing...more

What Public Companies Should Consider Since the NYSE and Nasdaq Have Issued Proposed Clawback Listing Standards

On October 26, 2022, the US Securities and Exchange Commission (SEC) announced the adoption of its new rules directing national securities exchanges, including the New York Stock Exchange (NYSE) and the Nasdaq Stock Market...more

FTC’s Proposed Ban on Noncompete Clauses May Have Far-Reaching Implications for Executive Compensation

The Federal Trade Commission (FTC) announced a notice of proposed rulemaking on January 5, 2023, that would ban employers from entering into or maintaining noncompete clauses with their workers. The proposal was issued in...more

Ready for a Sale? Part 2: Change in Control Provisions and Treatment of Outstanding Equity Compensation

This blog post is Part 2 in the “Ready for a Sale?” series, which is aimed at getting the human resources, benefits, and executive compensation functions of your organization ready for a potential sale or similar corporate...more

Ready for a Sale? Part 1: Prepare Executive Compensation Arrangements and Employee Benefit Plans

In light of the active M&A market, we think this spring could be an ideal time for companies to evaluate the order of their executive compensation arrangements and employee benefit plans, particularly companies that are...more

Reminder: No Need to Adopt Retirement Plans, ESOPs included, by End of 2021 for Tax Deduction Purposes

Before 2020, the IRS had long taken the position that an employee stock ownership plan (ESOP), and any other retirement plan for that matter, must be adopted no later than the end of the first tax year in which the employer...more

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