Nicholas Pension Consultants
Compensation Strategies Group, Ltd.
Nova 401(k) Associates
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|IRS Releases Advice Addressing Section 162(m) and CFO Compensation of Smaller Reporting Companies|
Pillsbury Winthrop Shaw Pittman LLP
Dec. 18, 2015
"Like smaller reporting companies, emerging growth companies (EGCs) are also entitled to rely on the limited disclosure rules in Item 402(m) of Regulation S-K. [IRS Chief Counsel Memorandum 2015 43003], however, does not address the applicability of its conclusion to EGCs. In addition, and most notably, the [CCA memorandum] does not address how [its] conclusion ... impacts the deductibility of compensation paid to a smaller reporting company's (or an EGC's) PFO before the release of this memorandum."
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