Section 162(m) of the Internal Revenue Code (Code) limits, subject to certain exceptions, a public company’s federal income tax deduction for compensation paid to any “covered employee” to $1 million in any taxable year. A...more
The Stunning Altera Case -
Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more
8/8/2015
/ Administrative Procedure Act ,
Chevron Deference ,
Corporate Taxes ,
Cost-Sharing ,
Foreign Subsidiaries ,
IRS ,
Parent Corporation ,
Section 482 ,
Stock Options ,
Stock-Based Compensation ,
Tax Court ,
Tax Deductions ,
Treasury
In 2010, the U.S. enacted a sweeping change in enforcement of its tax laws on foreign financial interests, the Foreign Account Tax Compliance Act (FATCA). The main thrust of the act is to penalize foreign financial...more
In IRS Notice 2014-19 and accompanying FAQs, the Internal Revenue Service (“IRS”) issued long-awaited guidance addressing the treatment of same-sex spouses under qualified retirement plans such as 401(k) and defined benefit...more
The U.S. Department of Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued guidance treating a same-sex couple as “married” for all Federal tax purposes as long as the couple was legally married in a state...more