Client Alert
IRS Reaffirms Its Position Restricting Availability of Performance-Based Compensation Deduction Exception Under Code Section 162(m)
February 27, 2008
Last week, the IRS issued a new revenue ruling confirming a recently released position that may have significant implications on the ability of public companies to deduct performance-based compensation in the event of an executive's termination due to good reason, involuntary termination without cause or retirement. This client alert summarizes the new ruling, Revenue Ruling 2008-13, and discusses the potential impact it may have on public companies seeking to deduct performance-based compensation under Code Section 162(m).
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If you have any questions regarding this client alert, please contact Bryan Tyson or Jane Jeffries Jones, the authors of this client alert, or you may contact either the Womble Carlyle attorney with whom you usually work or one of our Employee Benefits or Corporate and Securities attorneys listed on the following webpages:
Womble Carlyle Sandridge & Rice Employee Benefits Lawyers
Womble Carlyle Sandridge & Rice Corporate and Securities Lawyers
Womble Carlyle client alerts are intended to provide general information about significant legal developments and should not be construed as legal advice on any specific facts and circumstances, nor should they be construed as advertisements for legal services.
IRS CIRCULAR 230 NOTICE: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. tax advice within this client alert is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed in a client alert.
