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Year-End Deadline for Bonus and Performance-Based Equity Fast Approaching

October 13, 2009

An important deadline for amending executive bonus and other performance-based compensation arrangements is approaching quickly.  Public companies should review performance-based arrangements (e.g., bonus plans and equity awards) now to ensure compliance with changes announced by the Internal Revenue Service (IRS) under section 162(m) of the Code.  Generally, any necessary amendments to address these changes should be made by December 31, 2009.  Please see the attached memo for further information.