IRS Narrowly Interprets Some Exec Comp Transition Rules - McDermott Will & Emery

IRS Narrowly Interprets Some Exec Comp Transition Rules

Overview


Andrew Liazos said that Internal Revenue Service Notice 2018-68 offers a narrow interpretation of what constitutes a written, binding contract, which could mean that if a company elected to exercise a negative discretion provision and pay an executive less in performance compensation, the amount might not be fully deductible.