Guidance on Sections 162(m), 83 Due Soon, Treasury Official Says

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Final regulations under tax code Sections 162(m) and 83 are expected to come out “pretty soon,” while Section 162(m)(6) proposed regulations might be made final before the end of the year, a Treasury Department official said June 20 at an executive compensation conference.
Speaking unofficially, George H. Bostick, benefits tax counsel in Treasury's Office of Tax Policy, said the Section 162(m) proposed regulations (REG-137125-08) issued in 2011 dealt with two issues that Treasury and the Internal Revenue Service “tended to view as clarifications” (122 DTR G-9, 6/24/11).
First, the proposed regulations clarified the treatment under Section 162(m) of pre-initial public offering equity grants and second, the proposed regulations clarified that a plan must have a separate individual share limit, said another session speaker, Martha N. Steinman, a partner at Hogan Lovells in New York.

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