Section 162(m) of the Internal Revenue Code (“Code”), which disallows the deduction by any publicly held corporation with respect to certain compensation paid to a covered employee over $1,000,000, was amended by the 2017 Tax Cuts and Jobs Act (“TCJA”). One change made to Section 162(m) of the Code as part of the TCJA was
409A income inclusion
Proposed Changes to Section 409A are Welcome (for the Most Part)
By Melissa Ostrower on
Posted in Deferred and Executive Compensation, Section 409A
The Internal Revenue Service recently issued proposed regulations under Section 409A of the Internal Revenue Code (“Section 409A”) in an effort to clarify and modify parts of the current final regulations (issued in 2007) and proposed income inclusion regulations. For the most part, the proposed regulations are consistent with how most practitioners have been interpreting…