"[1] More entities are covered by the deduction limitations than you think! ... [2] Companies that are voluntary filers, voluntarily provide public disclosure, or are not subject to Exchange Act registration or reporting on the last day of the tax year are not subject to Section 162(m) limitations ... [3] Covered employees are not limited to those reported in the proxy or 10-K ... [4] The deduction limitations cannot be avoided by having another entity pay the compensation ... [5] The existence of a clawback policy could result in a loss of grandfathering and the retroactive loss of a deduction ... [6] Potential need to modify deferred compensation arrangements in 2020 ... [7] Compensation paid in another capacity or following termination of employment (even upon death) may not be deductible."  MORE >>