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Internal Revenue Service › Compensation Agreements

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.  
Venable LLP

IRS Ruling Provides Insights on Compensation Options for Managers of Tax-Exempt Bond-Financed Hotels, CCRCS and Similar Facilities

Venable LLP on

​​​​​​​Facilities owned by nonprofits and government entities are frequently financed with tax-exempt bonds and managed by for-profit management companies. To avoid tainting the tax-exempt status of the interest payable on...more

Amundsen Davis LLC

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

Amundsen Davis LLC on

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

Troutman Pepper

Proposed Section 162(m) Regulations Affect REIT Compensation Arrangements

Troutman Pepper on

Recently proposed IRS regulations reverse the reasoning of several past IRS private letter rulings regarding the application of the $1 million compensation cap of Section 162(m) to UPREIT structures in publicly traded REITs...more

White and Williams LLP

Proposed Regulations Broaden Limitation on Compensation Deductions for Public Companies

White and Williams LLP on

Internal Revenue Code Section 162(m) generally limits the amount of compensation to certain individuals (Covered Individuals) that a publicly traded company may deduct as a business expense. The Tax Cuts and Jobs Act (TCJA)...more

Polsinelli

IRS Guidelines Provide Greater Flexibility to Nonprofit Borrowers

Polsinelli on

New guidelines from the Internal Revenue Service substantially overhaul safe harbors that have existed for 20 years. Specifically, the IRS recently released Revenue Procedure 2017-13 (“Rev. Proc. 2017-13”), which establishes...more

Dickinson Wright

IRS Issues New Guidelines for Qualified Management Contracts for Facilities Financed with Tax Exempt Bonds

Dickinson Wright on

Health care providers with facilities financed with tax exempt bonds need to be aware of recent changes to the IRS rules for qualified management contracts. On August 22, 2016, the IRS issued Rev. Proc. 2016-44 which...more

McDermott Will & Emery

IRS Issues Regulations Affecting Compensation Arrangements at Tax-Exempt Organizations

McDermott Will & Emery on

On June 21, the IRS issued long awaited proposed regulations under Section 457 of the Internal Revenue Code that affect a broad range of compensation arrangements at tax exempt organizations. If a compensation arrangement is...more

Goodwin

New Proposed Treasury Regulations Focus on Management Fee Waivers

Goodwin on

On July 22, 2015, the U.S. Treasury Department and Internal Revenue Service released proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code relating to disguised payments for services between partners...more

Cooley LLP

Alert: IRS Issues Long-Awaited Proposed Regulations on Management Fee Waivers

Cooley LLP on

On July 22, 2015, the Treasury Department and the IRS published proposed regulations (the "Proposed Regulations") that address the circumstances in which allocations or distributions made by a partnership to a partner that...more

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