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Overview of Proposed Regulations Under Code Section 162(m) — Grandfather Rules

Series Installment: “publicly held corporation” - As we noted in our December 24, 2019 blog entry, on December 16, 2019, the Treasury Department released proposed regulations (the “Proposed Regulations”) addressing the...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

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

New Retirement Plan Design Opportunities Introduced by Recent Legislation

The Bipartisan Budget Act of 2018 (the “Budget Act”), which was adopted February 9, 2018, together with the Tax Cuts and Jobs Act (the “Tax Act”), which was adopted on December 22, 2017, and the Disaster Tax Relief and...more

Tracking Tax Reform: Capital Gains from Certain Partnership Profits Interests Subject to Extended Holding Period for Favorable Tax...

Under the “Tax Cuts and Jobs Act”, the recently enacted federal tax reform legislation (the “Act”), a new limitation applies to profits interest awards. Under the Act, income from “applicable partnership interests” will not...more

Tracking Tax Reform: The Executive Compensation and Employee Benefit Provisions of The Tax Bill

On December 20, 2017, the House of Representatives and the Senate voted to enact the tax reform bill, which has been renamed “To provide for reconciliation pursuant to titles II and V of the concurrent resolution on the...more

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