"[T]he city council in Portland, Ore., voted last week to impose a surtax on companies whose chief executives earn more than 100 times the median pay of their rank-and-file workers beginning next year.... As companies look to address the mechanics of the [Dodd-Frank] pay-ratio rules and prepare early disclosure models ... it's important to understand that the SEC has given companies broad leeway in calculating these ratios. If Portland or other jurisdictions decide they are going to impose a penalty based on ratios, we can expect that companies will take a hard look at the available alternatives and likely will become more aggressive with their method of calculation."

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