Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
How Tax Works - Entity Selection
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
Exámenes de constitucionalidad a la reforma tributaria ¿en qué vamos?
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
AGG Talks: Cross-Border Business - Corporate Considerations for Scaling Across Borders
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Spotlight Series: Beyond the Technical Side of Tax Law
10 Things Lawyers Should Know About BVI Transactions
JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
The Biden Tax Plan
Tax Planning Under a Biden Presidency
2020 Presidential Candidates' Tax Proposals
New anti-abuse provisions
Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Impact of environmental, social and governance agenda on tax
Section 162(m) of the Internal Revenue Code of 1986 (as amended, the “Code”) imposes a $1 million deductibility limit on compensation paid by “publicly held corporations” to “covered employees.” As reported in our previous...more
On April 10, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-22 (the “Revenue Procedure”), which (1) permits an “electing real property trade or business” that elected not to be subject to the...more
The Tax Cuts and Jobs Act of 2017 (TCJA) upended public company compensation structures nationwide. Prior to the TCJA, Section 162(m) of the Internal Revenue Code of 1986, as amended, generally provided for a $1 million...more
On December 20, 2019, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code....more
The Tax Cuts and Jobs Act of 2017 (TCJA) made significant changes to Section 162(m) of the Internal Revenue Code (Section 162(m)), expanding the scope of individuals and entities subject to Section 162(m), in addition to...more
Beginning with the 2018 tax year, nonprofit organizations that pay their top executives more than $1 million per year are subject to a new 21 percent excise tax. ...more
On August 21, the IRS issued Notice 2018-68, Guidance on the Application of Section 162(m) ("Notice"). Internal Revenue Code ("Code") Section 162(m) places a limitation on the amount publicly traded companies are permitted to...more
The Internal Revenue Service (the “IRS”) recently issued Notice 2018-68 (the “Notice”) that provides guidance regarding the application of Section 162(m) of the Internal Revenue Code of 1986, as amended (“Section 162(m)”)...more
On August 21, 2018, the IRS released Notice 2018-68 (“Notice”) providing its initial guidance on the Tax Cuts and Jobs Act (“Act”) transition rule for changes made to Section 162(m) of the Internal Revenue Code of 1986, as...more
Section 162(m) of the Internal Revenue Code of 1986, as amended (the “Code”), limits a publicly held corporation’s ability to take a corporate income tax deduction for compensation in excess of $1 million paid to “covered...more
On August 21, 2018, the IRS released Notice 2018-68 providing its initial guidance on the Tax Cuts and Jobs Act (Act) transition rule for changes under 162(m). Before the Act, 162(m) limited a public company’s tax deduction...more
Old Rule - Except for special rules that apply to public companies, the reasonable compensation of all employees is fully deductible as an ordinary and necessary business expense. Before this year the compensation...more
The Tax Cuts and Jobs Act (the “Tax Act”) has significant implications for public company executive compensation plans for tax years beginning after December 31, 2017 and will likely have a considerable impact on the future...more
The Administration’s frenzy to pass “tax reform” created tax breaks for some—I’m looking at you, the Trump family—increased taxes for others, and confusion for everyone, at least until the IRS is able to promulgate official...more
On December 22, 2017, President Trump signed the bill popularly referred to as the “Tax Cuts and Jobs Act” (the “Act”) into law. The Act contains significant changes to Section 162(m) of the Internal Revenue Code that are...more
On December 22, President Trump signed “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018” (“Bill”) into law. The Bill was previously named the...more
Section 162(m) of the Code generally disallows the deduction of compensation in excess of $1 million paid by a public company to a “covered employee” in any single taxable year. The Tax Act makes the following changes to...more
The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more
The “Bottom Line” - Learn the new rules for who is a “covered employee” and keep track of these individuals because “once a covered employee, always a covered employee” Evaluate compensation arrangements and contracts...more
On November 2, 2017, the Committee on Ways and Means of the U.S. House of Representatives released its tax reform bill titled the Tax Cuts and Jobs Act (the “House Bill”). On November 6, 2017, Kevin Brady, Chairman of the...more