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SEC Changes Requirements for Rule 10b5-1 Plans

On December 14, 2022, the SEC adopted amendments that significantly change the requirements for Rule 10b5-1 plans, including by imposing a 90 to 120 day cooling-off period for plans adopted by directors and officers, and...more

2022 Proxy Season Quick Reference Guide

The 2022 proxy season is just around the corner. This quick reference guide, which is intended to supplement Shearman & Sterling’s 19th Annual Corporate Governance & Executive Compensation Survey, summarizes themes from the...more

SEC Proposes Significant Changes to Rule 10B5-1 Plans and Introduces New Disclosure Requirements

Recent comments by former SEC Chair Clayton and current SEC Chair Gensler called renewed attention to Rule 10b5-1 plans, which had also received recent legislative interest in Congress, contributing to the current rule...more

California Voters Pass Ballot Initiatives on Worker Classification and Executive Pay

On November 3, 2020, California voters approved several ballot initiatives including Proposition 22, which exempts online-enabled applications and platforms (such as Uber, Lyft, Postmates, DoorDash and Instacart) from a state...more

New Disclosure Guidelines‘Perk-olating’

It is well known that the impact of the COVID-19 pandemic on business operations has directly affected executive compensation decision-making and related disclosures. With this backdrop, the Securities and Exchange Commission...more

Guide to the Evolving Workplace

Among its many impacts on society, COVID-19 has changed, perhaps permanently, how employees interact with each other and the workplace. As some businesses begin to reopen their doors to their workforce, they should consider...more

CEO Pay Ratio—Three-Year Refresher

It has been three proxy seasons since the CEO pay ratio became the mandatory disclosure for most U.S. public companies. The CEO pay ratio rules allow a registrant to use the same median employee for comparison purposes for up...more

IRS Proposes Carried Interest Rules Recharacterizing Certain Capital Gain in Connection with Profits Interests

On July 31, 2020, the Internal Revenue Service (IRS) published proposed regulations providing guidance under Section 1061 (the “Proposed Regulations”) of the Internal Revenue Code (the “Code”). Section 1061, which was added...more

Compensation and Governance Restrictions on CARES Act Stimulus Recipients - Update July 2020

We provide a deeper dive into the key stimulus programs under the CARES Act, as summarized in our client note “Congress Passes Largest Ever Economic Stimulus Package: Key Provisions of CARES Act.” The following table...more

DOL: Rollover Recommendations May Constitute Advice; Proposes Prohibited Transaction Exemption

In a proposed class prohibited transaction exemption published on June 29, 2020 (the “proposed exemption”), the Department of Labor (DOL) stated that advising employee benefit plan (“plan”) participants to roll over plan...more

Coronavirus Tax Relief Provisions Raise Surprising M&A Considerations

Two key provisions included in the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”)—the Paycheck Protection Program (PPP) and the Employee Retention Tax Credit (ERTC)—are raising surprising new issues in...more

Compensation and Governance Restrictions on CARES Act Stimulus Recipients - Update June 2020

We provide a deeper dive into the key stimulus programs under the CARES Act, as summarized in our client note “Congress Passes Largest Ever Economic Stimulus Package: Key Provisions of CARES Act.” The following table...more

DOL Offers Comfort to 401(k) Plan Fiduciaries Offering Private Equity Investments

Those responsible for overseeing their company’s 401(k) plan may be pleased to learn that recent DOL guidance provides that private equity investments may be offered to plan participants if included as part of a multi-asset...more

Washington State Becomes Next to Mandate Gender Diversity on Boards

Pursuant to the recently-amended Washington Business Corporation Act (WBCA), effective June 11, 2020, corporations subject to the WBCA that are public companies will be required to either have a “gender-diverse board” by...more

Key Considerations in Designing a Return to Work Plan

Although it is too early to know when America’s workforce will return to offices and other places of work, it is prudent for companies to start preparing for the return of employees to the physical workplace. This is...more

Compensation and Governance Restrictions on CARES Act Stimulus Recipients - Update April 2020

We provide a deeper dive into the key stimulus programs under the CARES Act, as summarized in our client note “Congress Passes Largest Ever Economic Stimulus Package: Key Provisions of CARES Act.” The following table...more

Key Considerations in Employee Terminations - April 2020

KEY CONSIDERATIONS IN EMPLOYEE TERMINATIONS - The rapid global spread of the novel coronavirus (COVID-19) has forced many businesses to operate with reduced staff, with some concluding that employee layoffs are necessary....more

Employee Furlough Considerations

In the wake of the market disruption caused by the COVID-19 outbreak, many employers are considering employee furloughs as an alternative to layoffs. Furloughs generally refer to a mandatory, but temporary, cessation from...more

Developments in Workplace Discrimination Guidance in the Wake of COVID-19

Many employers have been forced to consider employee layoffs, furloughs or salary reductions as a way to manage some of the financial hardship created by COVID-19. Companies should keep in mind existing federal, state and...more

Expanded Employee Leave: Application and Enforcement

The Families First Coronavirus Response Act (the “Families First Act” or the “Act”) requires covered employers to provide employees two weeks of paid sick leave and additional benefits for family leave due to the COVID-19...more

Considerations when Reducing Executive Salaries

In the wake of the market disruption caused by the COVID-19 outbreak, a number of employers have announced temporary salary reductions as a means of conserving cash, and thus demonstrating sound stewardship. This memorandum...more

Succession Planning in a Time of Crisis

Planning for an unexpected absence or loss of a key person is an important component of enterprise risk management. In the present environment, boards are meeting regularly in real time to address absences of key persons–both...more

Compensation and Governance Restrictions on CARES Act Stimulus Recipients

We provide a deeper dive into the key stimulus programs under the CARES Act, as summarized in our client note Congress Passes Largest Ever Economic Stimulus Package: Key Provisions of CARES Act. The following table summarizes...more

Qualified Retirement Plans During COVID-19: The CARES Act and Other Considerations

If you are a decision-maker or part of a COVID-19 response team at a U.S. business, you are making urgent, daily decisions that affect the health and wellbeing of your workers, customers and suppliers, as well as the...more

Key Considerations in Employee Terminations

The rapid global spread of the novel coronavirus (COVID-19) has forced many businesses to operate with reduced staff, with some concluding that employee layoffs are necessary. This memorandum discusses key considerations for...more

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