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Section 162(m): Actions That Should Be Taken by March 30, 2016, And/Or in This Year's Proxy to Avoid the $1,000,000 Deduction Limitation
Greenberg Traurig Link to more items from this source
[Guidance Overview]
Mar. 23, 2016

"For performance-based bonuses and other compensation for 2015 to qualify as 'performance- based compensation' that is exempt from Section 162(m), the Compensation Committee must certify in writing that the performance goals have been satisfied before the bonuses or other compensation is paid. To be exempt from the Section 162(m) deduction limitations, the Compensation Committee must set the performance goals during the first 90 days of the performance period. Thus, for a performance award for calendar year 2016, the goals must be set no later than March 30, 2016."

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