Undisclosed or inadequately disclosed executive perks continue to be a lightning rod for SEC Enforcement Actions.
While the SEC has not announced a formal perk disclosure enforcement program, the agency continues to pay very...more
Compensation committees should hire an independent legal expert to audit private jet and other perk disclosures on a privileged basis.
Given the SEC’s increased focus on perk disclosure, companies should evaluate their...more
Preliminary trends are emerging from the pay ratio disclosures filed by U.S. public companies in 2018.
Few companies use statistical sampling to identify their median employees and, instead, companies rely on a...more
3/22/2018
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CEOs ,
Cost-of-Living Adjustment (COLA) ,
Disclosure Requirements ,
Executive Compensation ,
Item 402 ,
Median Employee ,
Pay Ratio ,
Proxy Season ,
Publicly-Traded Companies ,
Regulation S-K ,
Securities and Exchange Commission (SEC)
Section 162(m) of the Internal Revenue Code (Code) limits, subject to certain exceptions, a public company’s federal income tax deduction for compensation paid to any “covered employee” to $1 million in any taxable year. A...more
The Securities and Exchange Commission (SEC) has adopted final rules under the Dodd-Frank Wall Street and Consumer Protection Act (the Dodd-Frank Act) to require U.S. public companies to disclose the ratio of the annual total...more