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Under New IRS Section 162(m) Guidance, Many Common Arrangements will not Retain Grandfathered Status

On August 21, 2018, the Internal Revenue Service (“IRS”) released Notice 2018-68 (the “Notice”), which clarifies a number of changes made to Section 162(m) of the Internal Revenue Code (the “Code”) by last year’s Public Law...more

Tax Reform to Impact Compensation Deduction Claimed by Foreign Private Issuers

While the recently enacted U.S. tax reform legislation did not overhaul executive compensation to the extent proposed in early forms of the bill, Section 162(m) of the U.S. Internal Revenue Code was dramatically revised in a...more

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