ARPA to Expand 162(m) Limits on Executive Compensation
On March 11, 2021, President Biden signed into law the American Rescue Plan Act of 2021 (the “ARPA”), the much-debated $1.9 trillion COVID-19 stimulus legislation. The ARPA includes a provision, added by Senate amendment on March 6, 2021, which will further limit the deductibility of amounts deemed to be “excessive employee remuneration” under Section 162(m) of the Internal Revenue Code of 1986, as amended (“Section 162(m)”) for tax years starting after December 31, 2026. This…