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Deduction Limitations Tax Deductions

Bennett Jones LLP

Canada Introduces "Excessive Interest and Financing Expenses Limitation"

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Multinational corporations, cross-border investments and many other Canadian public and private enterprises, will likely soon face a new and complex interest expense deduction limitation in Canada....more

Cooley LLP

Alert: IRS Issues Final Regulations Under Section 162(m)

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On December 18, 2020, the IRS issued final regulations under Section 162(m) of the Internal Revenue Code to reflect certain changes that were made to Section 162(m) by the Tax Cuts and Jobs Act of 2017. The final regulations...more

Locke Lord LLP

Holiday Stocking Stuffer: IRS Issues Proposed Regulations Under Code Section 162(m)

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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

Morrison & Foerster LLP

IRS Widens Scope Of Section 162(m) Deduction Limit

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Section 162(m) of the Internal Revenue Code (the “Code”) caps at $1 million a year a public corporation’s tax deduction for compensation paid to each of certain executive officers. As originally implemented, the regulations...more

Kelley Drye & Warren LLP

IRS Releases Initial 162(m) Guidance

IRC §162(m) limits a publicly held corporation’s ability to take a tax deduction for compensation paid to covered employees in excess of $1 million. As mentioned in our January 2018 Client Advisory, the Tax Cuts and Jobs Act...more

Nelson Mullins Riley & Scarborough LLP

Section 162(m) – The Narrow Path to Grandfathering

On August 21, 2018, the IRS released IRS Notice 2018-68 which contains much-anticipated initial guidance on the application of the grandfathering rules under amended Section 162(m) of the Internal Revenue Code. ...more

Sherman & Howard L.L.C.

IRS Issues Initial Guidance On Amended Code Section 162(m), Including Grandfathering Rules

The IRS recently released Notice 2018-68, providing long-awaited initial guidance on amendments made to Section 162(m) of the Internal Revenue Code by the Tax Cuts and Jobs Act of 2017 (TCJA). While the Notice only addressed...more

McGuireWoods LLP

IRS Releases New Guidance on Section 162(m) Covered Employees and Grandfathering Rules

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The IRS recently released guidance regarding the 2017 Tax Act amendments to Section 162(m) of the Internal Revenue Code, which generally apply to taxable years beginning or after Jan. 1, 2018. IRS Notice 2018-68 provides...more

Locke Lord LLP

Tracking Tax Reform IRS Issues Initial Guidance Under Section 162(m)

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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

Kilpatrick

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

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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

Cooley LLP

Alert: IRS Issues Guidance on Amended Section 162(m) Rules

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On Tuesday, the IRS issued widely-anticipated guidance regarding certain amendments that were made by the Tax Cuts and Jobs Act to Section 162(m) of the Internal Revenue Code. Under Section 162(m), compensation paid to a...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part IV: The IRC § 199A Deduction for Qualified Business Income—the Devil Is in the Details...

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BACKGROUND - The Tax Cuts and Jobs Act (“TCJA”) adopted a new 20% deduction for non-corporate taxpayers. It only applies to “qualified business income.” The deduction, sometimes called the “pass-through deduction,” is...more

Akin Gump Strauss Hauer & Feld LLP

Tax Cuts and Jobs Act

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

Skadden, Arps, Slate, Meagher & Flom LLP

"Executive Compensation and Benefits Report: Proposed Regulations Highlight the Complexity of the $500,000 Deduction Limit for...

On April 1, 2013, the Internal Revenue Service issued proposed regulations providing guidance on the $500,000 deduction limit for compensation paid by certain health insurance companies to their employees. Because of the...more

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