By Andrew Liazos and William R. Pomierski on Aug 27, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
On August 21, 2018, the IRS issued guidance regarding recent statutory changes made to Section 162(m) of the Internal Revenue Code. Overall, Notice 2018-68 strictly interprets the Section 162(m) grandfathering rule under the Tax Cuts and Jobs Act. Public companies and other issuers subject to these deduction limitations will want to closely consider this guidance...
Internal Revenue Service Updates Golden Parachute Payments Audit Technique Guide, Signaling Key Items IRS May Review on Audit
By Andrew Liazos, Ashley McCarthy and McDermott Will & Emery on Aug 24, 2017
Posted In IRS Guidance, Uncategorized
In early 2017, the IRS updated its Golden Parachute Payments Audit Technique Guide for the first time since its 2005 issuance. While intended as an internal reference for IRS agents conducting golden parachute examinations, the Audit Technique Guide offers valuable insight for both public and private companies, and recipients of golden parachute payments, into how...