On December 20, 2019, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code....more
The Tax Cuts and Jobs Act of 2017 (TCJA) made significant changes to Section 162(m) of the Internal Revenue Code (Section 162(m)), expanding the scope of individuals and entities subject to Section 162(m), in addition to...more
The Section 162(m) deduction limit for performance-based compensation was repealed by the Tax Cut and Jobs Act, effective for taxable years beginning after December 31, 2017, subject to transition relief. ...more
Code Section 162(m) Issues For Publicly-Held Employers to Consider for 2018 and Beyond - As we reported here, on December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (the “Act”). One of the...more
The Internal Revenue Service (IRS) has issued Notice 2018-68 (Notice) providing guidance on changes in Code Section 162(m) made by the Tax Cuts and Jobs Act of 2017 (TCJA), Public Law 115-17. The Notice has some good news and...more
The Internal Revenue Service (the “IRS”) recently issued Notice 2018-68 (the “Notice”) that provides guidance regarding the application of Section 162(m) of the Internal Revenue Code of 1986, as amended (“Section 162(m)”)...more
On August 21, 2018, the IRS issued Notice 2018-68 containing initial guidance on the application of amended Section 162(m) of the Internal Revenue Code of 1986 (Code). The notice describes how to identify “covered employees”...more
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
IRS Issues New 162(m) Guidance - August 21, 2018, the Internal Revenue Service (the “IRS”) issued Notice 2018-68 (the “Notice”) which provides initial guidance and clarification on amendments made to Section 162(m) of the...more
Last week, the Internal Revenue Service (the “IRS”) published limited initial guidance regarding key aspects of the changes brought about by the Tax Cuts and Jobs Act of 2017 (the “Act”) to Section 162(m) of the Internal...more
On August 21, the Internal Revenue Service (IRS) issued Notice 2018-68 containing much-awaited interpretive guidance on Section 162(m) of the Internal Revenue Code as amended by last year's tax reform act (Tax Act), including...more
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
On August 21, 2018, the Internal Revenue Service (the “IRS”) issued Notice 2018-68 (the “Notice”), offering initial guidance on changes made to Section 162(m) of the Internal Revenue Code (the “Code”) by the Tax Cuts and Jobs...more
On August 21, the IRS issued Notice 2018-68 to provide guidance on changes to Internal Revenue Code Section 162(m), enacted by the Tax Cuts and Jobs Act of 2017 (TCJA). Section 162(m) generally limits the tax deduction...more
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
As mentioned in a previous blog, the IRS has issued its initial guidance on Code Section 162(m), as modified by the Tax Cuts and Jobs Act. One important aspect of the guidance is its discussion of preserving deductibility...more
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
Section 162(m) of the Internal Revenue Code denies a tax deduction to a public company for compensation paid to certain individuals—called “covered employees”—to the extent that the compensation paid to such individual...more
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
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
On August 21, 2018, the IRS issued guidance regarding recent statutory changes made to Section 162(m) of the Internal Revenue Code. Overall, Notice 2018-68 strictly interprets the Section 162(m) grandfathering rule under the...more
On August 21, 2018, the IRS issued its initial guidance on the amendments to Section 162(m) made by the Tax Cuts and Jobs Act, in the form of Notice 2018-68. The guidance is fairly limited and does not completely address...more
With all the national press coverage about tax savings, tax cuts and company bonus payments associated with the Tax Cuts and Jobs Act of 2017 (the “Tax Act”), it is easy to miss the changes in federal tax laws that impose...more
Due to the varying methods of state conformity to the Internal Revenue Code, both the prior and current versions of Section 162(m) continue to be a consideration for state taxes....more
The final Tax Cuts and Jobs Act (the “Act”) signed into law December 22, 2017, and effective January 1, 2018, contained three significant changes to Internal Revenue Code section 162(m) in connection with reducing the...more