News & Analysis as of

Internal Revenue Service CFOs

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Rivkin Radler LLP

When A Shareholder Loses Control of Their S Corporation

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If given their druthers, most transactional corporate attorneys would prefer to spend their day practicing “happy law,” by which they typically mean transactions that involve capital formation, mergers and acquisitions, joint...more

Rivkin Radler LLP

Intercompany Loan Treated As Constructive Distribution and Contribution

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Heads I Win, . . . - When closely held corporations that are under common control engage in any intercompany transaction, it is prudent for the corporations and their shareholders to ensure that the transaction is being...more

Lowenstein Sandler LLP

Understanding the Corporate Transparency Act: Key Reporting Requirements and Deadlines for High Net Worth Individuals and...

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Much has been written in recent months alerting small business owners to the impending January 1, 2024 effective date of the Corporate Transparency Act (CTA).1 But do you know how the new reporting requirements will affect...more

Amundsen Davis LLC

IRS Issues Final Section 162(m) Regulations On Companies’ Ability To Deduct Executive Pay

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The Internal Revenue Service (IRS) recently published final regulations implementing changes made by the Tax Cuts and Jobs Act of 2017 (TCJA) to Section 162(m) of the Internal Revenue Code (Section 162(m)) expanding the scope...more

Womble Bond Dickinson

Proposed IRS 162(M) Regulations Effect Executive Compensation Arrangements

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The Internal Revenue Service (“IRS”) recently proposed Regulation 122180-18 (the “Proposed Regulations”) to implement the amendments found in the Tax Cuts and Jobs Act of 2017 (the “Act”)1 to Section 162(m) of the Internal...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Issues Anticipated Guidance on Covered Employees and Grandfathering Rules Under Code Section 162(m)

On August 21, 2018, the Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-68, which provides eagerly awaited guidance for changes that were made to Section 162(m) of the Internal Revenue Code...more

Womble Bond Dickinson

IRS Issues New Guidance for Smaller Reporting Companies on CFO Compensation

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In a recently released Chief Counsel Advice memorandum, the Internal Revenue Service (“IRS”) informally revised its guidance regarding which officers of “smaller reporting companies” (“SRCs”) should be considered “covered...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Releases Advice Addressing Section 162(m) and CFO Compensation of Smaller Reporting Companies

Section 162(m) of the Internal Revenue Code (Code) limits, subject to certain exceptions, a public company’s federal income tax deduction for compensation paid to any “covered employee” to $1 million in any taxable year. A...more

Locke Lord LLP

Recent CCM Provides that CFO of Small Reporting Companies May Be Subject to Code Section 162(m), Raises Questions for All Public...

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Since 2007, public companies have generally relied on a position taken by the IRS in Notice 2007-49 that a “covered employee” for determining who is subject to the $1 million deductibility limitations of Code Section 162(m)...more

WilmerHale

IRS Issues Guidance on the Applicability of Section 162(m) to CFO Compensation

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Summary: The IRS recently informally revised its guidance regarding which officers of public companies must be considered when determining the compensation deduction limitation of Section 162(m) of the Internal Revenue Code...more

Thomas Fox - Compliance Evangelist

Georgia On My Mind – How Does Compliance Enhance Shareholder Value?

Can you get a sense of place from listening to a song? In an article in the Financial Times (FT), entitled “The Life of a Song – Georgia On My Mind”, Mike Hobart wrote that when you “combine Stuart Gorrell’s lyrics with Hoagy...more

Saul Ewing Arnstein & Lehr LLP

Avoiding “Responsible Person” Liability For Payroll and Sales Taxes

One benefit of conducting business through a corporation, limited liability company or other limited liability entity is the “shield” from personal liability that these entities generally afford stockholders, directors and...more

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