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IRS Issues Proposed Regulations Under Code Section 162(m)
Wilmer Hale 
[Guidance Overview] Dec. 18, 2019 "Whether an arrangement is grandfathered must be determined by reference to applicable law.... Negative discretion still problematic, unless local law constrains use.... Vesting acceleration permitted under grandfather.... No IPO transition period.... Directors' fees and other non-employee compensation are subject to deduction disallowance.... Modification of 409A arrangements by December 31, 2020." MORE >> |
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