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IRS Issues Guidance on Section 162(m) Amendments (PDF)
ExeQuity 
[Guidance Overview] Sept. 4, 2018
"The most significant impact of the IRS Notice is that payments under the great majority of 162(m) 'umbrella' plans will not qualify for grandfathered deductibility under the TCJA.... [If] the company reserves the right to exercise negative discretion to reduce payments (which is a standard feature of 162(m) 'umbrella' plans), then the IRS Notice treats payments under the program as non-obligatory. Unless a portion of the payments under such a plan are mandated as a floor amount (which is rarely the case), the plan will not qualify for grandfathered deductibility."
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