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Accounting implications of IRC §162(m) limitations

 

Section 162(m) of the Internal Revenue Code limits the amount of compensation exceeding $1 million paid to certain employees that is deductible when determining taxable income for federal income tax purposes. The amount of compensation subject to this federal limitation is recognized as an expense for financial reporting purposes, but does not have a future tax consequence, resulting in a permanent difference between income reported for accounting purposes and taxable income. Determining whether amounts of compensation recognized for financial reporting purposes in the current period may be subject to the Section 162(m) limitation in future taxable periods may be challenging, but it is necessary to determine whether such amounts give rise to temporary or permanent differences under ASC 740, Income Taxes, and how these amounts may impact an entity’s effective tax rate.

 

Snapshot 2025-07, “Accounting implications of IRC §162(m) limitations,” discusses the limitations for compensation exceeding $1 million paid to certain employees that can be deducted when determining taxable income for federal income tax purposes under IRC Section 162(m), including how the revisions under the Tax Cuts and Jobs Act and the American Rescue Plan Act impact financial reporting.test

 

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