Read twice and referred to the Committee on Finance. (Sponsor introductory remarks on measure: CR S2738-2739: 3)
This bill amends Internal Revenue Code section 162(m) to expand the denial of a corporate tax deduction for certain excessive employee remuneration. It broadens the definition of “covered individual” to include any person performing services for the taxpayer for taxable years after December 31, 2024, and adds lookback coverage for certain previously reported top officers.
Progressives stress fairness and subsidy removal; conservatives stress business burden and overreach.
Relative to its intended legislative type, this bill is a focused substantive amendment to the Internal Revenue Code (section 162(m)) that expands the class of individuals whose remuneration may be subject to deduction denial.
This bill amends Internal Revenue Code section 162(m) to expand the denial of a corporate tax deduction for certain excessive employee remuneration.
It broadens the definition of “covered individual” to include any person performing services for the taxpayer for taxable years after December 31, 2024, and adds lookback coverage for certain previously reported top officers.
It revises the definition of publicly held corporation for the rule and grants the Treasury authority to issue regulations, including anti-avoidance rules for pass-through payments.
Broad, revenue-raising overhaul of corporate tax treatment faces strong stakeholder opposition and limited built-in compromise; passage needs major coalition or inclusion in larger tax legislation.
Relative to its intended legislative type, this bill is a focused substantive amendment to the Internal Revenue Code (section 162(m)) that expands the class of individuals whose remuneration may be subject to deduction denial. It provides explicit statutory language for several key definitions, updates the publicly held corporation definition, sets an effective date, and grants regulatory authority to the Treasury Secretary.
Progressives stress fairness and subsidy removal; conservatives stress business burden and overreach.
These are examples from the analysis, not a ranked list of the most-affected groups.
Progressives stress fairness and subsidy removal; conservatives stress business burden and overreach.
Likely supportive.
The bill closes a tax subsidy for large corporate bonuses and targets excessive executive pay.
Supporters would see it as addressing inequality and raising revenue, though revenue amounts and employer responses are uncertain.
Cautiously receptive.
The policy goal—limiting tax subsidies for very large pay—is defensible, but the bill raises implementation and administrative questions.
Support would depend on clear regulations, phase-in, and safeguards to avoid unintended consequences.
Likely opposed.
The bill is viewed as government overreach into private compensation, increasing tax burdens and regulatory complexity.
Conservatives would worry it discourages investment, harms competitiveness, and invites avoidance or litigation.
Reached or meaningfully advanced
Reached or meaningfully advanced
Still ahead
Still ahead
Still ahead
Broad, revenue-raising overhaul of corporate tax treatment faces strong stakeholder opposition and limited built-in compromise; passage needs major coalition or inclusion in larger tax legislation.
The bill has not accumulated any surfaced votes yet.
Progressives stress fairness and subsidy removal; conservatives stress business burden and overreach.
Broad, revenue-raising overhaul of corporate tax treatment faces strong stakeholder opposition and limited built-in compromise; passage nee…
Relative to its intended legislative type, this bill is a focused substantive amendment to the Internal Revenue Code (section 162(m)) that expands the class of individuals whose remuneration may be subject to deduction…
Go beyond the headline summary with full stakeholder mapping, legislative design analysis, passage barriers, and lens-by-lens tradeoff breakdowns.