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Locke Lord and Troutman Pepper will become Troutman Pepper Locke on January 1, 2025.
On December 18, 2020, the Internal Revenue Service (IRS) released final regulations (the “Final Regulations”) under Section 162(m) of the Internal Revenue Code, as amended by the Tax Cuts and Jobs Act of 2017 (“TCJA”). Section 162(m) generally limits the deductibility of compensation paid in any tax year to “covered employees” of a publicly held corporation to $1 million.
Read MoreOur last installment of our overview of the Proposed Regulations under Code Section 162(m) focuses on the transition or grandfather rules (“Grandfather Rules”) under the Proposed Regulations. Our prior installments have focused on the amendments to Code Section 162(m) enacted by the Tax Cuts and Jobs Act of 2017 (“TCJA”) and their effective date.
Read MoreThis installment of the overview of the Proposed Regulations under Code Section 162(m) focuses on the definition of what is “applicable employee remuneration.” As a reminder, Code Section 162(m) generally limits the compensatory deduction to the first $1 million of “applicable employee remuneration” paid by a publicly held corporation to each covered employee.
Read MoreToday’s installment of our overview of the Proposed Regulations under Code Section 162(m) highlights the expansion of who is a “covered employee.” As a reminder, Code Section 162(m) generally limits the compensatory deduction to the first $1 million of compensation paid by a publicly held corporation to each “covered employee.”
Read MoreAs we noted in our December 24, 2019 blog entry, on December 16, 2019, the Treasury Department released proposed regulations (the “Proposed Regulations”) addressing the amendments made to Internal Revenue Code Section 162(m) by the Tax Cuts and Jobs Act (the “Amendment”).
Read MoreOn December 16, 2019, the Treasury Department released proposed regulations (the “Proposed Regulations”) to address the amendments made to Code Section 162(m) by the Tax Cuts and Jobs Act (the “Amendment”). As background, the Amendment eliminated the exclusion attributable to qualified performance-based compensation from the $1 million cap on the deductibility of compensation paid to certain executives by a publicly held corporation.
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