In Notice 2018-68, the IRS has provided guidance with respect to executive compensation changes made by the Tax Cuts and Jobs Act. The changes include how the tax code limits the deduction for remuneration paid to certain executives by publicly held corporations, for tax years beginning after 12/31/17. Specifically, the Notice discusses the amended definition of covered employees and the operation of a grandfather rule. The deduction by a publicly held corporation for covered employee remuneration is disallowed to the extent it exceeds $1,000,000 in a tax year.
