The Internal Revenue Service (“IRS”) recently proposed Regulation 122180-18 (the “Proposed Regulations”) to implement the amendments found in the Tax Cuts and Jobs Act of 2017 (the “Act”)1 to Section 162(m) of the Internal Revenue Code of 1986, as amended (the “Code”). The Proposed Regulations supersede the IRS guidance previously released in IRS Notice 2018-682 and remain open for comment until February 18, 2020; however, many aspects of the Proposed Regulations take immediate effect. This alert summarizes key aspects the Proposed Regulations on executive compensation arrangements. READ MORE