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President's health insurance proposal receives chilly Democratic response

  • Faegre Baker Daniels
  • -
  • USA
  • -
  • February 2 2007

In his Jan. 23 State of the Union Address, President Bush outlined a new initiative to treat health insurance similar to the home mortgage interest deduction

Revenue Ruling 2008-13 provides prospective application of new service position on performance-based compensation exemption under Code Section 162(m)

  • Alston & Bird LLP
  • -
  • USA
  • -
  • February 25 2008

Under a new Revenue Ruling issued on February 21, 2008 (Rev. Rul. 2008-13), the Internal Revenue Service confirmed its reversal (as expressed in a January 2008 private letter ruling) of its prior position as to the effect of common severance provisions on the performance-based compensation exemption from Code Section 162(m) and, most significantly, provided a transition period for application of this new position

New IRS guidance complicates both executive bonus plans and deferred compensation arrangements

  • Ogletree Deakins
  • -
  • USA
  • -
  • February 25 2008

In Revenue Ruling 2008-13 (Feb. 21, 2008), the Internal Revenue Service (IRS) added an additional layer of complexity to drafting compensation arrangements for senior executives - an area of the law that already has been subjected to unprecedented changes as the result of Internal Revenue Code (IRC) Section 409A

Update to client memorandum on Section 162(m) of the Internal Revenue Code

  • Fried Frank Harris Shriver & Jacobson LLP
  • -
  • USA
  • -
  • February 25 2008

On February 4, 2008, Fried Frank issued a client memorandum describing a recent Private Letter Ruling in which the Internal Revenue Service (“IRS”) reversed its previous position on the effect that certain termination of employment provisions have on payments which are intended to qualify as “performancebased compensation” for purposes of section 162(m) of the Internal Revenue Code of 1986, as amended (the “Code”

Request for IRS guidance on Section 162(m) and performance-based compensation plans: White & Case weighs in

  • White & Case LLP
  • -
  • USA
  • -
  • February 25 2008

A recent Private Letter Ruling reversing the IRS's position on the tax code's $1 million cap on exemptions for performance-based compensation could have created difficulties for companies making decisions about their 2008 executive compensation awards and proxy reporting on award deductibility

IRS releases Revenue Ruling 2008-13 adopting position that performance-based compensation is non-excludable under 162(m) if also payable on termination without cause, for good reason or for voluntary retirement but prospective application

  • Fenwick & West LLP
  • -
  • USA
  • -
  • February 22 2008

On February 21, 2008, the IRS released Revenue Ruling 2008-13, confirming the position taken in PLR 200804004 that compensation intended to qualify as deductible performance-based compensation pursuant to Section 162(m) of the Internal Revenue Code of 1986, as amended, will not qualify as such if the recipient’s employment agreement provides for payment of the performance compensation upon a termination of employment without cause or for good reason, even if the performance metrics applicable to such compensation are satisfied

IRS guidance narrows performance-based compensation exemption from deduction limitation

  • Squire Sanders
  • -
  • USA
  • -
  • February 24 2008

Section 162(m) of the Internal Revenue Code, which prohibits a publicly held company from deducting more than US$1 million in annual compensation to its CEO and three highest-compensated officers (other than CEO and CFO), exempts performance-based compensation from such deduction limitation

Deduction at risk: IRS changes position on performance-based compensation exception under Section 162(m)

  • Vorys Sater Seymour and Pease LLP
  • -
  • USA
  • -
  • February 13 2008

The Internal Revenue Service recently issued Private Letter Ruling 200804004 (“PLR”) which appears to significantly limit the ability of publicly held corporations to use the performance-based compensation exception under Section 162(m) of the Internal Revenue Code

Section 409A action steps required in 2007

  • Alston & Bird LLP
  • -
  • USA
  • -
  • May 31 2007

This advisory focuses on action steps that must be taken during 2007 to comply with Section 409A

IRS announces limited transition relief

  • Squire Sanders
  • -
  • USA
  • -
  • February 28 2008

This is a follow-up to our February 18, 2008 Client Alert regarding a private letter ruling, PLR 200804004, that reversed the position taken by the IRS in two prior private letter rulings regarding circumstances under which compensation may qualify as performance-based compensation exempt from the Section 162(m) US$1 million deduction limitation

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