News & Analysis as of

U.S. Treasury Covered Employees

Eversheds Sutherland (US) LLP

Executive decision: IRS finalizes section 162(m) regulations

On December 18, 2020, the Internal Revenue Service and Treasury Department issued final regulations under section 162(m) of the Internal Revenue Code, following proposed regulations issued in December 2019. The final...more

Dechert LLP

And We Mean It - Proposed Regulation Doubles Down on the Elimination of the Performance-Based Exception Under Section 162(m) of...

Dechert LLP on

Last week, on December 20, 2019, the U.S. Department of the Treasury and Internal Revenue Service (the “IRS”) published a proposed regulation (the “Proposed Regulation”) under Section 162(m) of the Internal Revenue Code of...more

Eversheds Sutherland (US) LLP

IRS offers a 162(m) - brace for the holidays

On December 16, 2019, the Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) released long-awaited proposed regulations under Section 162(m) of the Internal Revenue Code implementing changes...more

Katten Muchin Rosenman LLP

Interim IRS Guidance on New Executive Compensation Requirements for Tax-Exempt Entities Creates New Challenges

Under new Section 4960 ("Section 4960") of the Internal Revenue Code of 1986, as amended ("IRC") that was adopted as part of the Tax Cuts and Jobs Act of 2017 (Tax Act), an excise tax under IRC Section 11 (currently 21...more

Proskauer - Not for Profit/Exempt...

IRS Releases Interim Guidance on New Excise Tax on Executive Compensation Paid by Tax-Exempt Organizations

On December 31, 2018, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released Notice 2019-09 (the “Notice”), which provides interim guidance under Section 4960 of the Internal Revenue...more

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