Insights
Alert
Samantha Nussbaum
Principal, Los Angeles, CA
Amendment to Section 162(M) Regulations
Alert | By Samantha Nussbaum
On March 31, 2015, the Treasury Department and the IRS issued final amended regulations under Section 162(m) to clarify that (1) stock plans must provide individual limits; and (2) RSUs granted by IPO companies must be paid prior to the end of the special transition period. Although many practitioners have been operating in accordance with the rules since they were proposed in 2011, all companies should confirm their stock plans comply and companies that are pre-IPO or recently had an IPO and are still within their transition period should review the final rules in order to make appropriate planning decisions with respect to upcoming equity awards.
Samantha Nussbaum
Principal
Samantha Nussbaum has consulted on behalf of public and private companies, compensation committees, and senior management on all aspects of executive compensation. Samantha’s consulting and legal background includes advising on executive compensation in the context of mergers and acquisitions, spin-offs, and initial public offerings; executive employment, severance, and change in control agreements; equity incentive plans; deferred compensation; and securities laws, including reporting and disclosure implications.