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IRS Proposes New 162(m) Regulations
Debevoise & Plimpton LLP Link to more items from this source
[Guidance Overview]
Jan. 24, 2025

"The proposed regulations define 'employee' using Section 3401(c), which includes both common-law employees and corporate officers.... The determination of which employees are among the five highest-compensated tracks tax principles, rather than SEC principles ... The proposed rules also apply the current Section 162(m) affiliated group rules to determinations of the five highest-compensated employees for each taxable year."  MORE >>

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