News & Analysis as of

Privately Held Corporations Tax Cuts and Jobs Act

ArentFox Schiff

What Private Companies and Family Offices Need to Consider in 2025

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Across all industries, private companies, family offices, and their owners and management teams face rapidly evolving challenges, opportunities, and risks in the dynamic environment that is 2025. Here are 11 issues that...more

ArentFox Schiff

What Private Companies Need To Consider in 2024: Top 10 Legal Issues

ArentFox Schiff on

Private companies and their owners face ever-evolving challenges as the market sees new regulations, new deal trends, and new risks in 2024. Below are 10 issues that the owners and leaders of privately held companies should...more

Akin Gump Strauss Hauer & Feld LLP

IRS Issues Final Regulations Regarding Certain Employee Remuneration in Excess of $1 Million Under Section 162(m) of the Code

Section 162(m) of the Internal Revenue Code of 1986 (as amended, the “Code”) imposes a $1 million deductibility limit on compensation paid by “publicly held corporations” to “covered employees.” As reported in our previous...more

Holland & Knight LLP

Proposed 162(m) Regulations Add Another Layer of Executive Compensation Issues in M&A

Holland & Knight LLP on

The Tax Cuts and Jobs Act of 2017 (TCJA) upended public company compensation structures nationwide. Prior to the TCJA, Section 162(m) of the Internal Revenue Code of 1986, as amended, generally provided for a $1 million...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Pillsbury Winthrop Shaw Pittman LLP

The IRS Issues 83(i) Guidance: Opportunity to “Opt Out”

IRS guidance on new law permitting income tax deferral for private company equity compensation awards provides clarity by introducing more rules. The Section 83(i) deferral opportunity is only available for awards granted...more

Opportune LLP

How Section 83(i) in the Tax Cuts & Jobs Act of 2017 Benefits Workers

Opportune LLP on

The Tax Cuts and Jobs Act of 2017 (“The Act”) is just over a year old and tax practitioners, taxpayers and commentators are still working to digest the actual effect of many of its sweeping changes. While one of the central...more

Troutman Pepper Locke

Potential Benefits and Hurdles of New Rule Affecting Private Company Equity Award Grantees - Tax Update Volume 2019, Issue 1

Troutman Pepper Locke on

A much-touted change in employee compensation was instituted by the Tax Cuts and Jobs Act of 2017, but whether it will be a much-used election remains to be seen. ...more

White & Case LLP

IRS Issues Guidance on the Deferral of Income from Private Corporation Stock Options and Restricted Stock Units

White & Case LLP on

On December 22, 2017, the Tax Cuts and Jobs Act (the "Act") was signed into law. The Act added a new Section 83(i) to the Internal Revenue Code of 1986, as amended (the "Code"), pursuant to which certain employees of eligible...more

Harris Beach Murtha PLLC

IRS Issues Initial Guidance on Deferral Option for Qualified Equity Grants

On December 22, 2017, President Trump signed the Tax Cuts and Jobs Act ("TCJA") into law. One of the lesser publicized changes enacted by the TCJA was the introduction of new Internal Revenue Code ("Code") Section 83(i),...more

Miles & Stockbridge P.C.

Two Cheers for Deferred Taxation of Qualified Equity Grants

The Tax Cuts and Jobs Act added a new tax deferral to encourage private corporations to grant more equity awards. If you’re thinking about it, consider whether the juice is worth the squeeze....more

Benesch

U.S. Tax Reform: Key Considerations for Non-U.S. Families with Connections to the United States

Benesch on

The Tax Cuts and Jobs Act (the Act) was signed into law on December 22, 2017. The Act is without a doubt the most impactful reform to the Internal Revenue Code since the tax reform of 1986. While it does not appear that the...more

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