Excerpt: The scope of the deduction restriction is broad ? generally, any companies that are in the same 'controlled group' as a health insurer (as broadly defined in PPACA) may be subject to the $500,000 limitation. And the provision will impact the deductibility of compensation forservices performed beginning in 2010. Thus, any company with a 'health insurer' in its controlled group should quickly become familiar with this new rule. This memorandum will outline how the new restriction operates.