Category Archives: IRC Section 162(m)

Subscribe to IRC Section 162(m) RSS Feed

Senate Stays Up Late to Approve Tax Bill

Early in the morning on Saturday, December 2, 2017 (it was nearly 2 AM Eastern!), the Senate voted 51-49, drawn mostly along party lines, to pass its version of the tax reform bill described in our previous blog posts Thanksgiving Tax Frenzy – New Tax Bill Proposes Executive Compensation Changes That Could Derail Deferred Compensation … Continue Reading

Startups Have Much To Be Thankful For – Senate Amendments to New Tax Bill Remove Deferred Compensation and Stock Options from Endangered Species List

As discussed in our November 14, 2017 blog post, Thanksgiving Tax Frenzy – New Tax Bill Proposes Executive Compensation Changes That Could Derail Deferred Compensation and Stock Options, the evolution of the Tax Cuts and Jobs Act bill in both the House and the Senate is very fluid. No sooner had we posted the previous entry … Continue Reading

Thanksgiving Tax Frenzy – New Tax Bill Proposes Executive Compensation Changes That Could Derail Deferred Compensation and Stock Options

Congress has been in a frenzy to try and get new tax legislation passed by Thanksgiving, and members of the House and Senate would presumably rather be enjoying a feast rather than drafting and analyzing additional tax provisions when Turkey day rolls around. This blog addresses the executive compensation related provisions in the proposed new tax … Continue Reading

IRS Confirms Significant Change in the Landscape of 162(m) Performance-Based Compensation Arrangements

  On February 21, 2008, the Internal Revenue Service (“IRS”) released Revenue Ruling 2008-13, which confirms and expands upon the position taken in Private Letter Ruling (“PLR”) 200804004 that compensation intended to qualify as “performance-based compensation” under Section 162(m) of the Internal Revenue Code of 1986, as amended (the “Code”), will not be exempt from … Continue Reading

Significant Change in the Landscape of 162(m) Performance-Based Compensation Arrangements

On January 25, 2008, the Internal Revenue Service (“IRS”) released Private Letter Ruling (“PLR”) 200804004. This new PLR has apparently reversed an important position that served as guidance to public companies and practitioners regarding the tax deductibility of certain performance-based pay under Section 162(m) of the Internal Revenue Code of 1986, as amended (the “Code”). … Continue Reading
LexBlog