IRS Prop. Reg.: ABA Tax Comments on Employee Remuneration in Excess of $1 Million (IRC §162)

Nov. 20, 2020, 5:00 AM

ABA Tax Section November 20 released comments on REG-122180-18 that would provide guidance on the limitation of the deduction for certain employee remuneration in excess of $1 million. The proposed regulations would provide a definition of publicly held corporation as any corporation that issues securities required to be registered under section 12 of the Exchange Act or that is required to file reports under section 15(d) of the Exchange Act. The ABA Tax Section makes several recommendations to be included in the final regulations mostly concerning tax code Section 409A deferred compensation and the “partnership rule” from the proposed ...

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