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Under New IRS Section 162(m) Guidance, Many Common Arrangements Will Lose Grandfathered Status
Dorsey & Whitney LLP 
Sept. 21, 2018
"[Notice 2018-68] provides a number of examples of its interpretations of the amended Code Section 162(m) that are not always intuitive.... In addition, there are a number of areas that still require future guidance, including what modifications will be permitted with respect to deferred compensation plans that require a payment delay until such payment will be fully deductible by the company, as permitted under Section 409A of the Code."
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