News & Analysis as of

Internal Revenue Code (IRC) Executive Compensation Tax Planning

DLA Piper

Tax Considerations for Public Company Equity Incentive Awards

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This is the third part of a series covering certain securities law, corporate governance, and tax considerations related to stock options and restricted stock unit (RSU) awards granted by public companies....more

Morgan Lewis - ML Benefits

IRS Proposes Regulations on Expanded Definition of Covered Employee Under Code Section 162m

Section 162(m) of the Internal Revenue Code prohibits a publicly held corporation from taking compensation-related tax deductions with respect to the compensation of a “covered employee” to the extent the compensation exceeds...more

Goodwin

Internal Revenue Code Section 162(m): Proposed Regulations

Goodwin on

On January 14, 2025, the Internal Revenue Service and the US Treasury Department issued proposed regulations under Section 162(m) of the Internal Revenue Code (Code) to implement changes under the American Rescue Plan Act of...more

Cooley LLP

Proposed Regulations Issued Under Internal Revenue Code § 162(m)

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Changes effective starting on January 1, 2027 - In the last few days preceding President Donald Trump’s inauguration, the IRS under the Biden administration proposed regulations to implement amendments to Internal Revenue...more

Goodwin

Fiscalité des « management packages »

Goodwin on

La loi de finances pour 2025 prévoit l’instauration d’un régime fiscal et social spécifique pour les gains réalisés par les managers à raison des participations qu’ils détiennent dans les groupes dans lesquels ils exercent...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Proposes New Rules to Implement the Expanded $1 Million Limit on Deductible Pay for Publicly Held Corporations

New proposed regulations under Section 162(m) of the Internal Revenue Code would further limit deductibility of executive compensation paid by a publicly held corporation....more

Nutter McClennen & Fish LLP

IRS Issues New Proposed Regulations Under 162(m)

On January 14, 2025, the Internal Revenue Service (the “IRS”) issued new proposed regulations under section 162(m) of the Internal Revenue Code (the “Code”), supplementing regulations already in effect. Under section 162(m),...more

Lowenstein Sandler LLP

The Impact of 457A on Deferred Compensation from non-US Entities

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Today on “Just Compensation,” Darren Goodman, Megan Monson, and Taryn E. Cannataro of Lowenstein's Employee Benefits & Executive Compensation group are joined by Sophia Mokotoff, partner in the firm’s Tax group, to discuss...more

Williams Mullen

[Webinar] Winter Tax Forum - January 19th, 9:00 am - 10:00 am ET

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We hope you can join us for our Winter Tax Forum on Thursday, January 19, 2023. Employee benefits and executive compensation partner Nona Massengill will provide an overview of the tax issues that impact equity...more

Groom Law Group, Chartered

[Webinar] COVID-19 Legislative Update – Health, Pension and Tax Provisions in the American Rescue Plan Act - March 16th, 1:00 pm -...

On March 10, 2021, the House of Representatives passed the American Rescue Plan Act (H.R. 1319, the “Act”), sending it to President Biden for his signature later this week. The Act includes a number of significant health,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Certain Deferred Compensation Plans Must Be Amended by December 31, 2020

Transition relief for amending nonqualified deferred compensation (NQDC) plans to reflect the 2017 amendments to Section 162(m) of the Internal Revenue Code will expire on December 31, 2020. ...more

Morgan Lewis

IRS Releases Proposed Regulations on Executive Compensation for Tax-Exempt Organizations

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The Internal Revenue Service and US Department of the Treasury have released proposed regulations governing the excise tax imposed by Internal Revenue Code Section 4960 on certain executive compensation paid to employees of...more

Seyfarth Shaw LLP

Executive Compensation at Tax-Exempt Organizations Back in the Limelight – IRS Issues New Guidance

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Seyfarth Synopsis: The IRS recently issued proposed regulations providing guidance under Internal Revenue Code (“Code”) Section 4960, which provides for an excise tax on tax-exempt organizations that pay certain executives in...more

Cozen O'Connor

IRS Issues Proposed Regulations for Tax on Nonprofit Executive Compensation

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The Internal Revenue Service has issued proposed regulations describing the rules regarding the 21 percent excise tax on compensation over $1 million and excess parachute payments paid by tax-exempt organizations to certain...more

Proskauer - Employee Benefits & Executive...

New Excise Tax For Tax-Exempts Can Ensnare For-Profit Employers: Comment Deadline Fast Approaching

As discussed, the IRS’s initial interpretation of a new excise tax under Section 4960 of the Internal Revenue Code could catch for-profit employers who set up foundations, trusts, PACs, and other tax-exempt entities off...more

Holland & Knight LLP

IRS Notice Provides Guidance for Exempt Organizations on Excise Tax

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• The Internal Revenue Service (IRS) released IRS Notice 2019-09 (Notice) offering guidance under Section 4960 of the Internal Revenue Code as added by the Tax Cuts and Jobs Act. • Section 4960 applies to certain...more

Troutman Pepper Locke

Potential Benefits and Hurdles of New Rule Affecting Private Company Equity Award Grantees - Tax Update Volume 2019, Issue 1

Troutman Pepper Locke on

A much-touted change in employee compensation was instituted by the Tax Cuts and Jobs Act of 2017, but whether it will be a much-used election remains to be seen. ...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part VIII: Charitable and Tax-Exempt Organizations / Estate and Gift Taxes

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Charitable organizations work hard to maintain exempt status. These organizations operate in a highly regulated landscape: In exchange for enjoying freedom from income taxes, they must comply with strict organizational and...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

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