Proposed Code Section 162(m) RegulationsPDF
The proposed Code Section 162(m) regulations were published in the Federal Register on December 20, 2019. The proposed regulations are extensive and cover a good amount of new ground. This IPB client alert covers some highlights of the proposals:
- The covered employee “once-always” rule.
- Grandfather rule for multi-year incentive arrangements.
- Grandfather rule for nonqualified deferred compensation plans.
- Compensation subject to the limit.
- Disregarded entities.
- Covered employee SEC disconnect.
- 409A plans delaying payout.
- Predecessor entities.
To read our full analysis and get links to our prior coverage of 162(m), click "Client Alert".