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Edward A. Razim III

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On January 16, the Internal Revenue Service (IRS) published proposed regulations (90 FR 4691) under Section 162(m) of the Internal Revenue Code. 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.…

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…

The economic uncertainty of the COVID-19 pandemic has forced many employers to furlough or layoff a significant percentage of their workforce.  These workforce reductions may inadvertently cause a “partial termination” of the employer’s qualified retirement plan triggering a requirement that all affected participants become 100% vested in their plan accounts. …

On August 8, 2020, President Trump issued the Presidential Memorandum on Deferring Payroll ‎Tax Obligations in Light of the Ongoing COVID-19 Disaster (the “Executive Order”).  The ‎Executive Order instructed the Treasury Department to provide guidance authorizing employers ‎to defer the collection and deposit of employee payroll tax obligations.  On August

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On July 31, 2020, the Internal Revenue Service and the U.S. Treasury Department issued ‎Proposed Treasury Regulations (the “Proposed Regs”) providing guidance under the ‎‎“carried interest” rules of Section 1061 of the Internal Revenue Code of 1986, as amended ‎‎(the “Code”).  Please see our Quick Study “IRS Issues Carried…

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On May 21, 2020, the U.S. Department of Labor (“DOL”) announced a new safe harbor rule that will allow plan sponsors, by default, to post retirement plan disclosures online or deliver them to participants by email in satisfaction of their duties under the Employee Retirement Income

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Today’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.”  …