News & Analysis as of

Internal Revenue Code (IRC) Deferred Compensation Tax Deductions

Freeman Law

Tax Court in Brief | Hoops, LP v. Commissioner: Deductibility of Deferred Compensation

Freeman Law on

Tax Litigation: The Week of February 21, 2022, through February 25, 2022 - Hicks v. Comm’r, T.C. Memo. 2022-10 | February 23, 2022 | Gale, J. | Dkt. No. 10406-17 - Hoops, LP v. Comm’r, T.C. Memo. 2022-9 | February 23,...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Public Company Nonqualified Plan Amendments May Be Required by December 31: The Law of Unintended Consequences Strikes Again

The Internal Revenue Code is famously complicated, and changes to discrete parts of the code - such as those adopted by the Tax Cuts and Jobs Act of 2017 (TCJA) - have a notorious history of leading to unpredictable and...more

Latham & Watkins LLP

10 Key Takeaways From the Section 162(m) Proposed Regulations

Latham & Watkins LLP on

Recently issued proposed regulations clarify changes made by the TCJA to the tax deductibility of executive compensation. Section 162(m) of the US Internal Revenue Code (the Code) as amended by the Tax Cuts and Jobs Act...more

Rosenberg Martin Greenberg LLP

Final Section 199A Regulations: Interpretation of W-2 Wages and UBIA Thresholds May Significantly Limit the QBI Deduction

When it was announced that the Tax Cuts and Jobs Act included a new 20% deduction for qualified business income (“QBI”) of pass-through businesses, many business owners started planning for huge tax savings. Hopefully, their...more

Holland & Knight LLP

Seven Tips for Tribal Governments to Reduce Tribal Member Taxes in 2019

Holland & Knight LLP on

• With Democrats taking control of the U.S. House of Representatives, tax provisions affecting tribal governments and their members are once again on the table for discussion. • This notice provides an overview of seven...more

McDermott Will & Emery

Tax Reform Surprises and Strategies with the New 162(m) Rules

McDermott Will & Emery on

Section 162(m) of the Internal Revenue Code (Code) previously limited the tax deduction to $1M annually for covered employee compensation paid by a company that is publicly traded, subject to some important exceptions. The...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part VI: Employment and Fringe Benefit Related Provisions

Foster Garvey PC on

BACKGROUND - The Tax Cuts and Jobs Act (“TCJA”) creates, modifies or eliminates a number of employment and employee fringe benefit related provisions of the Code. Both employers and employees need to be aware of these...more

Skadden, Arps, Slate, Meagher & Flom LLP

Section 162(m) After the Tax Cuts and Jobs Act: What to Do Now

On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (the Act), which includes significant changes to the executive compensation deduction rules in Section 162(m) of the Internal Revenue Code (Code)...more

McGuireWoods LLP

The New Tax Rules for Executive Compensation and Employee Benefits

McGuireWoods LLP on

On Dec. 22, President Trump signed into law the 2017 Tax Act, the most comprehensive set of changes to the Internal Revenue Code since 1986. Some of the changes affect executive compensation and employee benefits. Because...more

Goodwin

2017 Tax Law's Impact on Compensation and Benefits

Goodwin on

On December 20, 2017, Congress passed the Tax Cuts and Jobs Act (the Act), which President Trump indicated he would sign. It is a sweeping tax bill with the potential to significantly alter executive compensation and employee...more

Proskauer - Tax Talks

To Accelerate or Not? Potential Tax Planning in Light of Proposed Reforms to Code Section 162(m)

Proskauer - Tax Talks on

Under both the House and Senate versions of the Tax Cuts and Jobs Act, Internal Revenue Code Section 162(m) would be modified to expand the scope of companies and executive officers subject to the limitation on deductibility...more

Proskauer - Tax Talks

Comparison of the Executive Compensation Provisions in the Tax Cuts and Jobs Act

Proskauer - Tax Talks on

On November 20, 2017, the Senate Finance Committee released legislative text of its version of the Tax Cuts and Jobs Act, which contains proposals modifying certain executive compensation provisions of the Internal Revenue...more

Seyfarth Shaw LLP

Tax Reform: Employee Benefits

Seyfarth Shaw LLP on

This is the first issue in a planned series of alerts for employers on selected topics on tax reform. The series of Tax Reform Management Alerts is designed to provide an in-depth analysis of executive compensation and...more

Wilson Sonsini Goodrich & Rosati

Proposed Tax Reform Bills of Senate and House Now Aligned on Key Compensation and Benefits-Related Tax Provisions

This WSGR Alert provides a high-level comparison of the latest tax reform proposals from the U.S. House of Representatives and the U.S. Senate as they relate to compensation and benefits matters....more

Ballard Spahr LLP

Federal Tax Reform: The Senate Bill – Comparison to the House Bill, and Evaluating the Bigger Picture

Ballard Spahr LLP on

The Senate Finance Committee released a detailed description of the Senate's tax reform bill, titled the Tax Cuts and Jobs Act, on November 9. The Committee has not released the text of the bill, and likely will not do so...more

Sheppard Mullin Richter & Hampton LLP

Thanksgiving Tax Frenzy – New Tax Bill Proposes Executive Compensation Changes That Could Derail Deferred Compensation and Stock...

Congress has been in a frenzy to try and get new tax legislation passed by Thanksgiving, and members of the House and Senate would presumably rather be enjoying a feast rather than drafting and analyzing additional tax...more

Proskauer - Tax Talks

Tax Planning Under the Tax Cuts and Jobs Act: Flow-Throughs Are the Answer to Everything

Proskauer - Tax Talks on

The tax reform bills introduced in the House of Representatives and the Senate dramatically reduce the corporate tax rate from 35% to 20% and create added incentives for taxpayers to invest capital into U.S. businesses with...more

Fenwick & West LLP

Proposed Senate Bill Revives Concern of Adverse Impact on Equity and Performance-Based Compensation

Fenwick & West LLP on

The Joint Committee on Taxation released a description of the Senate Chairman’s Mark to the proposed Tax Cuts and Jobs Act on November 9, 2017, reintroducing adverse equity and performance-based compensation tax provisions...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

Dechert LLP

House Tax Reform Bill Released: Would Cause Major Changes to US Tax System

Dechert LLP on

The U.S. House of Representatives GOP conference released its long-awaited tax reform bill, the Tax Cuts and Jobs Act (the “House Bill”), on Thursday, November 2, 2017. ...more

Hogan Lovells

New Draft Tax Bill Provisions Have the Potential to Dramatically Alter Executive Compensation

Hogan Lovells on

The new draft tax bill, unveiled last week by the Trump administration has many provisions which would significantly affect many businesses in the United States. This post does not focus on all of the implications for the...more

Jackson Lewis P.C.

The Proposed Tax Cuts And Jobs Act Would Make Sweeping Changes To Executive Compensation And Employee Benefits

Jackson Lewis P.C. on

On November 2, 2017, the U.S. House of Representatives unveiled the Tax Cuts and Jobs Act (H.R. 1) (the “Bill”) as part of proposed tax reform legislation. The Bill is sweeping in scope and provides for significant changes to...more

Ballard Spahr LLP

GOP Tax Bill Outlines Significant Changes for Benefits and Compensation

Ballard Spahr LLP on

The Committee on Ways and Means yesterday released the proposed Republican tax reform bill, titled the "Tax Cuts and Jobs Act." Although the proposed bill makes major changes to individual and corporate tax provisions in many...more

Proskauer - Employee Benefits & Executive...

Tax Reform Proposal Takes Aim at Executive Compensation

On February 26, 2014, U.S. Congressman Dave Camp released a comprehensive tax reform proposal that includes several provisions intended to limit or restrict executive compensation. Congressman Camp’s proposal includes the...more

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