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Tax Deductions Covered Employees

Fisher Phillips

How Will Non-Profits Be Impacted by the Big Beautiful Bill? Your Guide to Key Changes Affecting Charitable Giving, Excise Taxes,...

Fisher Phillips on

President Donald Trump signed a massive budget bill last month – the “One Big Beautiful Bill Act” (OBBBA) – and it significantly impacts non-profits and tax-exempt organizations. While some of the new changes may be...more

Gould + Ratner LLP

The Latest COVID-19 Stimulus: Highlights of Key Tax Provisions in the American Rescue Plan Act of 2021

Gould + Ratner LLP on

The American Rescue Plan Act of 2021 (ARPA, 2021) was signed by President Biden on March 11, 2021 to address the continuing economic impact on employers and employees the coronavirus (COVID-19) pandemic has posed. The ARPA...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

Ogletree, Deakins, Nash, Smoak & Stewart,...

Public Company Nonqualified Plan Amendments May Be Required by December 31: The Law of Unintended Consequences Strikes Again

The Internal Revenue Code is famously complicated, and changes to discrete parts of the code - such as those adopted by the Tax Cuts and Jobs Act of 2017 (TCJA) - have a notorious history of leading to unpredictable and...more

Perkins Coie

IRS Announces Delay of Certain Periods for 1031 Transactions

Perkins Coie on

In response to the ongoing coronavirus pandemic (COVID-19), the Internal Revenue Service (the IRS) has taken additional actions intended to provide immediate relief to taxpayers. Delay of Identification and Acquisition...more

Seyfarth Shaw LLP

An Electing Real Property Trade or Business can Revoke its Election on Account of the Change to Qualified Improvement Property...

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On April 10, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-22 (the “Revenue Procedure”), which (1) permits an “electing real property trade or business” that elected not to be subject to the...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

Latham & Watkins LLP

10 Key Takeaways From the Section 162(m) Proposed Regulations

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Recently issued proposed regulations clarify changes made by the TCJA to the tax deductibility of executive compensation. Section 162(m) of the US Internal Revenue Code (the Code) as amended by the Tax Cuts and Jobs Act...more

Troutman Pepper Locke

IRS Issues Proposed Regulations On Section 162(M)'s Executive Compensation Deductibility Cap

Troutman Pepper Locke on

On December 20, 2019, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code....more

BCLP

Highlights from Proposed Section 162(m) Regulations

BCLP on

Section 162(m) of the Internal Revenue Code disallows a deduction by any publicly held corporation for applicable employee remuneration paid with respect to any covered employee to the extent that remuneration for the taxable...more

Herbert Smith Freehills Kramer

New Section 162(m) Proposed Regulations

The Tax Cuts and Jobs Act of 2017 (TCJA) made significant changes to Section 162(m) of the Internal Revenue Code (Section 162(m)), expanding the scope of individuals and entities subject to Section 162(m), in addition to...more

Eversheds Sutherland (US) LLP

IRS offers a 162(m) - brace for the holidays

On December 16, 2019, the Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) released long-awaited proposed regulations under Section 162(m) of the Internal Revenue Code implementing changes...more

Proskauer - Not for Profit/Exempt...

Five Excise Tax Tips For Tax-Exempt Employers

As we have previously discussed, the 2017 tax reform act created a new excise tax under section 4960 of the Internal Revenue Code that will affect many tax-exempt employers. The tax is 21% of certain compensation and can be...more

McDermott Will & Schulte

Changes in Executive Compensation

In a presentation at McDermott’s Employment and Employee Benefits Forum, Andrew Liazos discussed areas of focus for Section 162(m) and third-party loan funding for employee stock purchase plans (ESPPs). He also provided...more

Katten Muchin Rosenman LLP

Considerations and Challenges Under New IRS Guidance on Section 162(m)

On August 21, the IRS issued Notice 2018-68, Guidance on the Application of Section 162(m) ("Notice"). Internal Revenue Code ("Code") Section 162(m) places a limitation on the amount publicly traded companies are permitted to...more

Cadwalader, Wickersham & Taft LLP

New IRS Guidance Regarding Section 162(m)’s Deduction Limitation for Executive Compensation – Increased Complexity and Reduced...

The Internal Revenue Service (the “IRS”) recently issued Notice 2018-68 (the “Notice”) that provides guidance regarding the application of Section 162(m) of the Internal Revenue Code of 1986, as amended (“Section 162(m)”)...more

Brownstein Hyatt Farber Schreck

IRS Guidance Clarifies Some TCJA Changes to the $1 Million Deduction Limit for Executive Compensation under Code Section 162(m)

Section 162(m) of the Internal Revenue Code of 1986, as amended (the “Code”), limits a publicly held corporation’s ability to take a corporate income tax deduction for compensation in excess of $1 million paid to “covered...more

Fenwick & West LLP

New 162(m) Guidance: IRS Notice 2018-68 Clarifies Scope of Tax Reform and Transition Rules

Fenwick & West LLP on

Section 162(m) of the Internal Revenue Code denies a tax deduction to a public company for compensation paid to certain individuals—called “covered employees”—to the extent that the compensation paid to such individual...more

Snell & Wilmer

The 162(m) Transition Rule Guidance Has Arrived

Snell & Wilmer on

On August 21, 2018, the IRS released Notice 2018-68 providing its initial guidance on the Tax Cuts and Jobs Act (Act) transition rule for changes under 162(m). Before the Act, 162(m) limited a public company’s tax deduction...more

Saul Ewing LLP

IRS Guidance on Compensation Deduction Limits for Public Companies

Saul Ewing LLP on

On August 21, 2018, the Internal Revenue Service (“IRS”) issued Notice 2018-68 (“Notice”) which provides initial guidance on amendments made by the Tax Cuts and Jobs Act of 2017 (“Tax Act”) under Section 162(m) of the...more

Holland & Hart - Employers' Lawyers

What Do Your Executives Have In Common With Seven-Figure Income College Coaches?

Tax-exempt organizations may be surprised to learn of the practical impact of a statute enacted as part of the Tax Cuts and Jobs Act in December 2017. Section 4960 of the Internal Revenue Code immediately put in place...more

Snell & Wilmer

Tax Cuts and Jobs Act: Implications for Public Company Executive Compensation Programs

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The Tax Cuts and Jobs Act (the “Tax Act”) has significant implications for public company executive compensation plans for tax years beginning after December 31, 2017 and will likely have a considerable impact on the future...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part VI: Employment and Fringe Benefit Related Provisions

Foster Garvey PC on

BACKGROUND - The Tax Cuts and Jobs Act (“TCJA”) creates, modifies or eliminates a number of employment and employee fringe benefit related provisions of the Code. Both employers and employees need to be aware of these...more

WilmerHale

Tax Act: Deductibility of Executive Compensation After Tax Reform

WilmerHale on

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

Schwabe, Williamson & Wyatt PC

Tax Reform: What Does the Tax Cuts and Jobs Act Mean for the Transportation, Ports and Maritime Industry?

The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more

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