77th Institute on Federal Taxation

Overview


Andrew Liazos will deliver a presentation entitled, “162(m) Deduction Limitations and Transition Rules” at the 77th Institute on Federal Taxation in both New York and San Diego.

This presentation will explore sweeping changes to the deduction limitations applicable to top executive compensation under Code Section 162(m), including eliminating the exemption for stock options, bonuses, and other “performance-based compensation,” adding the CFO to the list of affected executives, and dropping the exemption for compensation paid after termination of service.

Transition rules were added for written binding contracts in place as of November 2, 2017, which, during the initial years of dealing with these changes, may be as important as the changes themselves. This session explains the changes, analyzes the transition rules, discusses the IRS’ new regulations, and makes practical recommendations for managing exposure and risk on a prospective basis.