Jeff Tenenbaum’s message in the EO Tax Journal’s EOTJ Mailbag regarding the NFL’s decision to relinquish its federal tax-exempt status and the challenges it may face during the conversion process:

“Paul, as you know, the NFL’s announcement yesterday about its decision to voluntarily relinquish its federal tax-exempt status made big news across the country. As a nonprofit lawyer, to me, the far more interesting issue is the question of exactly how the NFL plans to go […]

New final regulations1 (the “Final Regulations”) have been issued clarifying and altering the “qualified performance-based compensation” exception and the transitional “reliance period” exception for newly public companies to the $1 million limit on deductible compensation for covered employees of public companies.
Overview
Section 162(m) generally limits deductions by publicly held corporations for remuneration paid to “covered employees” in excess of $1 million per year.2

Public corporations nevertheless can deduct the whole amount of compensation paid to “covered […]