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man with coins Unlike any of the prior definitions of covered employee subject to the $1 million deduction limitation, the ARPA expansion brings non-officers into the definition of covered employees .(Photo: Shutterstock)

On December 16, 2019, the Internal Revenue Service (IRS) released proposed regulations (REG-122180-18) under Internal Revenue Code (IRC) section 162(m), which is the tax provision that generally imposes a $1 million annual limit on deductions by a publicly held corporation for compensation paid to certain top executives.

John Schultz is a Managing Director with the Compensation and Benefits group of Alvarez & Marsal. He specializes in compensation and benefits planning and consulting.

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