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IRS Releases Advice Addressing Section 162(m) and CFO Compensation of Smaller Reporting Companies
Pillsbury Winthrop Shaw Pittman LLPLink to more items from this source
[Guidance Overview]
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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