Section 162(m) Final Regulations Clarify Requirements for Exemptions to $1 Million Deduction Limitation


Joseph Adams, Andrew Liazos, William Pomierski, and Ruth Wimer wrote this bylined article on IRS final regulations governing Section 162(m) requirements for performance-based pay. “Public companies with stock-based plans that are intended to comply with the requirements for performance-based compensation should confirm that their plan document sets forth the required individual per-employee limit,” the authors wrote, adding that companies planning IPOs “should evaluate whether it remains appropriate to grant performance-based restricted stock units or performance shares.” Read the full article