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IRS Issues Proposed Regulations on the Expanded Definition of "Covered Employee" Under Code Section 162(m)

On January 16, the Internal Revenue Service (IRS) published proposed regulations ( 90 FR 4691) under Section 162(m) of the Internal Revenue Code. Section 162(m) generally limits the deductibility of compensation paid in any...more

Has Your Retirement Plan Experienced a Partial Plan Termination?

The economic uncertainty of the COVID-19 pandemic has forced many employers to furlough or layoff a significant percentage of their workforce. Among the issues an employer should consider in a furlough or layoff context is...more

Has Your Retirement Plan Experienced a Partial Plan Termination?

The economic uncertainty of the COVID-19 pandemic has forced many employers to furlough or layoff a significant percentage of their workforce. These workforce reductions may inadvertently cause a “partial termination” of the...more

Initial Thoughts Regarding the IRS’ Employee Payroll Tax Deferral Guidance in IRS Notice 2020-65

On August 8, 2020, President Trump issued the Presidential Memorandum on Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster (the “Executive Order”). The Executive Order instructed the Treasury...more

IRS Issues Carried Interest Guidance

On July 31, 2020, the Internal Revenue Service and the U.S. Treasury Department issued Proposed Treasury Regulations (the “Proposed Regs”) providing guidance under the “carried interest” rules of Section 1061 of the Internal...more

CARES Act Guide: Overview of IRS Guidance Regarding the Employee Retention Credit

The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) was signed into law on March 27, 2020. Section 2301 of the CARES Act provides for a refundable payroll tax credit (the “Retention Credit”) for 50% of...more

CARES Act Guide: Overview of IRS Guidance Regarding Deferral of Employment Tax Deposits and Payments

The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) was signed into law on March 27, 2020. One form of economic assistance under the CARES Act provides short-term payroll tax relief by allowing employers...more

Holiday Stocking Stuffer: IRS Issues Proposed Regulations Under Code Section 162(m)

On December 16, 2019, the Treasury Department released proposed regulations (the “Proposed Regulations”) to address the amendments made to Code Section 162(m) by the Tax Cuts and Jobs Act (the “Amendment”). As background,...more

IRS Announces 2019 Retirement Plan Limitations – Certain Limits are Increased

The Internal Revenue Service announced the 2019 cost-of-living adjustments to the dollar limitations for qualified retirement plans and other benefits, and the Social Security Administration announced its own cost-of-living...more

Tracking Tax Reform IRS Issues Initial Guidance Under Section 162(m)

On August 21, 2018, the IRS issued Notice 2018-68 providing initial guidance on the amendments made to Section 162(m) of the Internal Revenue Code of 1986 (the “Code”) by the 2017 tax reform bill, which has been renamed “To...more

IRS Issues Proposed Regulations Affecting Deferred Compensation Plans of Tax-Exempt Organizations

On June 21, 2016, after more than 15 years of ongoing deliberations, the U.S. Department of the Treasury (the Dept. of Treasury) issued proposed regulations under Section 457 of the Internal Revenue Code of 1986 (the Code),...more

Recent CCM Provides that CFO of Small Reporting Companies May Be Subject to Code Section 162(m), Raises Questions for All Public...

Since 2007, public companies have generally relied on a position taken by the IRS in Notice 2007-49 that a “covered employee” for determining who is subject to the $1 million deductibility limitations of Code Section 162(m)...more

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