Posted: 2/29/2008

Last week, the IRS issued a Revenue Ruling addressing the scope of the "performance-based compensation" exception to the $1 million deduction limitation under Code Section 162(m). The Revenue Ruling follows an outcry from public companies and their advisors over a recent private letter ruling on the same issue. In the attached memorandum, we summarize the Revenue Ruling and suggest steps that public companies should take in response.

If you have any questions, please contact John McGuiness.