Lois Colbert

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Initial Post-Tax Reform 162(m) Guidance Issued – A Reasonable Grandfather and a Covered Employee Surprise

On August 21, 2018, Treasury and IRS released Notice 2018-68, their initial guidance on the application of Code section 162(m) after Tax Reform (including the operation of the grandfather provision for compensation required...more

8/27/2018 / Compensation & Benefits , Deduction Limitations , Executive Compensation , Internal Revenue Code (IRC) , IRS , Section 162(m) , Securities and Exchange Commission (SEC) , Tax Cuts and Jobs Act , Tax Deductions , Tax Reform

House Ways and Means Committee Says, “Never Mind” to Repeal and Replace of Code Section 409A

One week ago the Republicans’ Tax Bill H.R. 1, the “Tax Relief and Jobs Act,” was released. Section 3801 of that bill proposed to significantly curtail deferred compensation arrangements by replacing Internal Revenue Code...more

11/10/2017 / Deferred Compensation , Internal Revenue Code (IRC) , IRS , Section 409A , Tax Reform

IRS Provides Guidance for the Post-Determination Letter Era

In July of 2015, the IRS announced that it would end its regular determination letter program for individually designed plans effective January 1, 2017. At the time of this announcement, many plan sponsors and other...more

10/20/2016 / Determination Letter , Employee Benefits , EPCRS , Internal Revenue Code (IRC) , IRS , Qualified Retirement Plans

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