22 August 2018 IRS provides initial guidance under Section 162(m) on identifying covered employees and applying the grandfather rule The IRS has published (Notice 2018-68) initial guidance on applying Section 162(m) as amended by the Tax Cuts and Jobs Act of 2017 (TCJA). Section 168(m)(1) generally allows a publicly held company to claim a deduction for $1 million or less in remuneration paid to a covered employee; the TCJA added a transition rule under Section 162(m) that grandfathered certain outstanding arrangements. Notice 2018-68 provides guidance on the amended rules for identifying covered employees and operation of the grandfather rule. A Tax Alert on Notice 2018-68 is forthcoming. Document ID: 2018-1667 |
