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Tax Reform Surprises and Strategies with the New 162(m) Rules

Section 162(m) of the Internal Revenue Code (Code) previously limited the tax deduction to $1M annually for covered employee compensation paid by a company that is publicly traded, subject to some important exceptions. The...more

House Tax Bill Would Gut Deferred Compensation Plans and Curtail Executive Pay Deductions

The US House of Representatives Committee on Ways and Means proposed Tax Cuts and Jobs Act intends to reduce corporate and individual tax rates. To pay for the proposed changes, the House Tax Bill would, if enacted,...more

Review of Section 409A Proposed Regulations

On June 22, 2016, the Internal Revenue Service (IRS) issued proposed changes to the regulations under the Internal Revenue Code (Code) ยง409A. The Code intends to clarify or modify a wide range of very restrictive rules...more

IRS Provides New 409A Guidance; New Proposed Regulations Provide Additional Clarity, Warn of Abusive Practices, and Present...

In Depth - Additional flexibility to use Section 409A exemptions - ..Expanded availability of the rules for transaction-based compensation for stock rights and incentive stock options. The final regulations allow...more

IRS Issues Regulations Affecting Compensation Arrangements at Tax-Exempt Organizations

On June 21, the IRS issued long awaited proposed regulations under Section 457 of the Internal Revenue Code that affect a broad range of compensation arrangements at tax exempt organizations. If a compensation arrangement is...more

Camp Tax Reform Proposal Could Impact Executive Compensation

On February 26, 2014, U.S. House of Representatives Committee on Ways and Means Chairman Dave Camp (R-MI) released the proposed Tax Reform Act of 2014 (the Camp Proposal), which would simplify the Internal Revenue Code and...more

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